Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Section 194H applies only where the recipient earns commission or brokerage while acting in a representative capacity for the payer. An online ticketing platform that dealt independently with customers, controlled platform data, bore operational risks, remained liable for platform claims and remitted a fixed ticket amount irrespective of collections operated on a principal-to-principal basis. Its retained convenience fee for digital booking services was therefore not commission paid or constructively paid by the cinema operator, and no tax-deduction obligation arose. Interest for failure to deduct tax was consequential to the primary obligation and was deleted. A separate unchallenged demand remained unaffected.
Section 194H applies only where the recipient earns commission or brokerage while acting in a representative capacity for the payer. An online ticketing platform that dealt independently with customers, controlled platform data, bore operational risks, remained liable for platform claims and remitted a fixed ticket amount irrespective of collections operated on a principal-to-principal basis. Its retained convenience fee for digital booking services was therefore not commission paid or constructively paid by the cinema operator, and no tax-deduction obligation arose. Interest for failure to deduct tax was consequential to the primary obligation and was deleted. A separate unchallenged demand remained unaffected.
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