Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Seeking a lower deduction of tax certificate (“LDC”) - LDC was grated for TDS @ 0.5% instead of @ 0.01% as sought - The reasons furnished by the Respondent No. 1 qua the Application i.e., as to why the Petitioners’ request that TDS should not be deducted at a rate of 0.01% (zero point zero one per cent), hinges on broad generalizations in relation to the propriety of projected estimations of revenue and tax liability, and accordingly has been has been issued mechanically reflecting non-application of mind. - Directions issued to consider the case of the assessee - HC
Seeking a lower deduction of tax certificate (“LDC”) - LDC was grated for TDS @ 0.5% instead of @ 0.01% as sought - The reasons furnished by the Respondent No. 1 qua the Application i.e., as to why the Petitioners’ request that TDS should not be deducted at a rate of 0.01% (zero point zero one per cent), hinges on broad generalizations in relation to the propriety of projected estimations of revenue and tax liability, and accordingly has been has been issued mechanically reflecting non-application of mind. - Directions issued to consider the case of the assessee - HC
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