Revenue-neutral domestic transfer pricing and mirror transactions justified deletion of related-party adjustments for operation, maintenance and port ...
Rectification u/s 154 - non deduction of TDS u/s 194I - The Tribunal examined the rectification proceedings and found that the Assessing Officer's actions were not sustainable in law. Despite previous rectifications in favor of the assessee, the AO pursued further rectification, incorrectly asserting TDS liabilities. The Tribunal held that such rectification, involving detailed inquiries, was not permissible under legal precedent. Therefore, the lower authorities erred in treating the assessee as the assessee-in-default under section 201, and the rectification was deemed not sustainable.
Rectification u/s 154 - non deduction of TDS u/s 194I - The Tribunal examined the rectification proceedings and found that the Assessing Officer's actions were not sustainable in law. Despite previous rectifications in favor of the assessee, the AO pursued further rectification, incorrectly asserting TDS liabilities. The Tribunal held that such rectification, involving detailed inquiries, was not permissible under legal precedent. Therefore, the lower authorities erred in treating the assessee as the assessee-in-default under section 201, and the rectification was deemed not sustainable.
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