Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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Tax deducted at source that is subsequently deposited into the Government Treasury should not remain recoverable as principal TDS liability once the remittance is verified. Interest for delayed remittance continues to apply, but only up to the actual date of deposit; challans, payment dates and correlation with the demand require verification before recomputation. Renewable Energy Certificate registration charges require examination of the payment's nature, recipient, supporting invoice or demand, and statutory basis. Where the charges qualify as statutory or registration fees not subject to TDS, the related demand and interest should be deleted; otherwise, liability must be determined under the applicable law.
Tax deducted at source that is subsequently deposited into the Government Treasury should not remain recoverable as principal TDS liability once the remittance is verified. Interest for delayed remittance continues to apply, but only up to the actual date of deposit; challans, payment dates and correlation with the demand require verification before recomputation. Renewable Energy Certificate registration charges require examination of the payment's nature, recipient, supporting invoice or demand, and statutory basis. Where the charges qualify as statutory or registration fees not subject to TDS, the related demand and interest should be deleted; otherwise, liability must be determined under the applicable law.
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