Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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TDS u/s 195 - The agent may be main client, but the law mandates that the non-resident should be the main client of the agent. Therefore, this reasoning of the Ld. CIT(A) cannot be affirmed. The A.O. has also observed that 52% of the revenue of the agent is from non-resident. In our view, 52% of the revenue would not make the agent falling in the category of the working mainly for the non-resident.
TDS u/s 195 - The agent may be main client, but the law mandates that the non-resident should be the main client of the agent. Therefore, this reasoning of the Ld. CIT(A) cannot be affirmed. The A.O. has also observed that 52% of the revenue of the agent is from non-resident. In our view, 52% of the revenue would not make the agent falling in the category of the working mainly for the non-resident.
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