Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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TDS u/s 195 - assessee has already deducted tax under section 192 of the Act in respect of salary cost of expatriate employees - where profit attribution to a PE is based on a notional calculation rather than actual payments (e.g., markup on salaries of expatriate employees), the assessee cannot be expected to deduct tax on such notional income, especially when tax has already been deducted on the actual payments under different sections of the Income-tax Act. - AT
TDS u/s 195 - assessee has already deducted tax under section 192 of the Act in respect of salary cost of expatriate employees - where profit attribution to a PE is based on a notional calculation rather than actual payments (e.g., markup on salaries of expatriate employees), the assessee cannot be expected to deduct tax on such notional income, especially when tax has already been deducted on the actual payments under different sections of the Income-tax Act. - AT
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