Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Tax deduction at source under section 194H requires the assessee to make a commission payment within a principal-agent relationship. Where a principal directly credits retailer incentives and deducts tax under the intermediary's PAN, the intermediary's recording of gross receipts and retailer shares for Form 26AS reconciliation does not establish receipt of that share as income or a separate payment from its own funds. Trade incentives or discounts in principal-to-principal transactions therefore do not attract the withholding obligation or consequential disallowance.
Tax deduction at source under section 194H requires the assessee to make a commission payment within a principal-agent relationship. Where a principal directly credits retailer incentives and deducts tax under the intermediary's PAN, the intermediary's recording of gross receipts and retailer shares for Form 26AS reconciliation does not establish receipt of that share as income or a separate payment from its own funds. Trade incentives or discounts in principal-to-principal transactions therefore do not attract the withholding obligation or consequential disallowance.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
