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Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Tax deduction at source on leave travel concession reimbursements involving a foreign travel leg was not required where operative interim High Court directions restrained such deduction. Although the foreign travel component was not exempt, the assessee-bank was bound to comply with the interim directions and could not deduct tax contrary to them. Non-deduction during the period those directions remained operative therefore did not render the bank an assessee in default. Consequent demands for tax and interest were deleted.
Tax deduction at source on leave travel concession reimbursements involving a foreign travel leg was not required where operative interim High Court directions restrained such deduction. Although the foreign travel component was not exempt, the assessee-bank was bound to comply with the interim directions and could not deduct tax contrary to them. Non-deduction during the period those directions remained operative therefore did not render the bank an assessee in default. Consequent demands for tax and interest were deleted.
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