Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Rule 37BA(2) declaration requirements are procedural where a trust has offered interest income to tax and tax was deducted on that income under the trustee's PAN. The absence of the declaration or a corresponding Form 26AS entry in the trust's PAN does not, by itself, defeat substantive entitlement to TDS credit. Credit should be granted where the trust establishes that the income was included in its taxable return and the deducted tax relates to that income.
Rule 37BA(2) declaration requirements are procedural where a trust has offered interest income to tax and tax was deducted on that income under the trustee's PAN. The absence of the declaration or a corresponding Form 26AS entry in the trust's PAN does not, by itself, defeat substantive entitlement to TDS credit. Credit should be granted where the trust establishes that the income was included in its taxable return and the deducted tax relates to that income.
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