Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Section 205 protects a salary recipient from direct tax recovery to the extent tax has already been deducted from salary, even where the corresponding TDS credit is not fully reflected in Form 26AS. Responsibility for depositing deducted tax and correctly reporting it lies with the employer-deductor, who may be treated as an assessee in default for non-compliance. Claimed TDS must be factually verified through supporting evidence and, where necessary, confirmation or records from the deductor. Pending rectification requests require examination after hearing the taxpayer, followed by rectification or amendment of outstanding demands where the TDS claim is established.
Section 205 protects a salary recipient from direct tax recovery to the extent tax has already been deducted from salary, even where the corresponding TDS credit is not fully reflected in Form 26AS. Responsibility for depositing deducted tax and correctly reporting it lies with the employer-deductor, who may be treated as an assessee in default for non-compliance. Claimed TDS must be factually verified through supporting evidence and, where necessary, confirmation or records from the deductor. Pending rectification requests require examination after hearing the taxpayer, followed by rectification or amendment of outstanding demands where the TDS claim is established.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
