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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Revision u/s 263 - As per CIT assessee firm has paid interest on unsecured loan of 3 ex-partners but not deducted TDS on the interest amount so paid as per provision of section 194A - the assessee has failed to demonstrate on merits that the view taken by the AO before passing assessment order was a plausible view as being taken after due enquiries on the issue under consideration. Thus, we uphold the finding of the PCITin categorizing the assessment as erroneous so far as prejudicial to the interest of the Revenue - AT
Revision u/s 263 - As per CIT assessee firm has paid interest on unsecured loan of 3 ex-partners but not deducted TDS on the interest amount so paid as per provision of section 194A - the assessee has failed to demonstrate on merits that the view taken by the AO before passing assessment order was a plausible view as being taken after due enquiries on the issue under consideration. Thus, we uphold the finding of the PCITin categorizing the assessment as erroneous so far as prejudicial to the interest of the Revenue - AT
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