Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
TDS u/s 195 - grossing up - the obligation to pay the tax is on the recipient and since the assessee in terms of the agreement agreed to pay the taxes, the same has to be necessarily added to the income of the recipient and therefore, the principle of grossing up has to be applied.
TDS u/s 195 - grossing up - the obligation to pay the tax is on the recipient and since the assessee in terms of the agreement agreed to pay the taxes, the same has to be necessarily added to the income of the recipient and therefore, the principle of grossing up has to be applied.
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