Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Commission expenses paid to its holding company - Whether such payments were at arm's length or were for business expediency? - Revenue has accepted the identical expenses incurred by the assessee in the other assessment years - The disallowance was made on account of non-deduction of TDS under section 195 of the Act. Thus it can be inferred that the question of arm length and business expediency does not arise in the given facts and circumstances. - AT
Commission expenses paid to its holding company - Whether such payments were at arm's length or were for business expediency? - Revenue has accepted the identical expenses incurred by the assessee in the other assessment years - The disallowance was made on account of non-deduction of TDS under section 195 of the Act. Thus it can be inferred that the question of arm length and business expediency does not arise in the given facts and circumstances. - AT
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