Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Denial of TDS credit - non-deposit by employer - the Revenue in terms of Section 205 of the Act, is restrained from enforcing any tax recovery against the assessee insofar as the demand with reference to the amount of tax which had been deducted by the employer from the salary accrued to assessee and assuming that the deductor-employer had not remitted the amount after its deduction to the Central Government, the only course open to the Revenue is to recover same from the very person who has deducted the TDS and not from appellant assessee. - AT
Denial of TDS credit - non-deposit by employer - the Revenue in terms of Section 205 of the Act, is restrained from enforcing any tax recovery against the assessee insofar as the demand with reference to the amount of tax which had been deducted by the employer from the salary accrued to assessee and assuming that the deductor-employer had not remitted the amount after its deduction to the Central Government, the only course open to the Revenue is to recover same from the very person who has deducted the TDS and not from appellant assessee. - AT
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