Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Revision u/s 263 - Disallowance u/s 40(a)(ia) on non deduction of TDS - The Tribunal found that the Principal Commissioner had incorrectly invoked section 263 as the payments and Tax Deducted at Source (TDS) were related to the subsequent financial year and there was no revenue implication or prejudice to the Revenue.
Revision u/s 263 - Disallowance u/s 40(a)(ia) on non deduction of TDS - The Tribunal found that the Principal Commissioner had incorrectly invoked section 263 as the payments and Tax Deducted at Source (TDS) were related to the subsequent financial year and there was no revenue implication or prejudice to the Revenue.
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