Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Credit of TDS - consideration received for offshore supply of rolling stock, when no corresponding income has been offered for taxation by the assessee - The ITAT cited precedent to assert that TDS credit should be granted regardless of whether the income was directly offered for taxation, as long as TDS was deducted and deposited with the government. - The Tribunal upheld the assessee's entitlement to TDS credit and subsequent refunds, in alignment with previous rulings and provisions of the Income Tax Act.
Credit of TDS - consideration received for offshore supply of rolling stock, when no corresponding income has been offered for taxation by the assessee - The ITAT cited precedent to assert that TDS credit should be granted regardless of whether the income was directly offered for taxation, as long as TDS was deducted and deposited with the government. - The Tribunal upheld the assessee's entitlement to TDS credit and subsequent refunds, in alignment with previous rulings and provisions of the Income Tax Act.
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