Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Fixed "refurbish and rebate" credit notes issued to distributors for defective products did not constitute consideration for contract work where the credit was uniformly calculated at 30% of the original price, regardless of repair cost or whether repairs occurred, and distributors were not obliged to repair. Consequently, tax was not required to be deducted at source and the related disallowance was deleted. Employees' welfare contributions require verification against statutory due dates using challans and supporting material where the tax audit report's payment dates are disputed. Contributions paid within the prescribed due dates must be allowed; the issue was remanded for limited verification.
Fixed "refurbish and rebate" credit notes issued to distributors for defective products did not constitute consideration for contract work where the credit was uniformly calculated at 30% of the original price, regardless of repair cost or whether repairs occurred, and distributors were not obliged to repair. Consequently, tax was not required to be deducted at source and the related disallowance was deleted. Employees' welfare contributions require verification against statutory due dates using challans and supporting material where the tax audit report's payment dates are disputed. Contributions paid within the prescribed due dates must be allowed; the issue was remanded for limited verification.
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TaxTMI 
TaxTMI 
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