Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
TDS u/s 194C - Non deduction of TDS on payment to the persons who were not the owner of the vehicle - The Tribunal interpreted the term "owns" in section 194C(6) to encompass possession rather than strict registered ownership. Referring to section 44AE, which defines "owner" for the purpose of presumptive taxation, the Tribunal concluded that ownership includes possession of the goods carriage, not just registered ownership. Citing judicial precedents and the intention of the legislature to provide benefits to taxpayers, the Tribunal determined that the appellant complied with section 194C(6) by obtaining declarations from those in possession of the goods carriages and making payments accordingly.
TDS u/s 194C - Non deduction of TDS on payment to the persons who were not the owner of the vehicle - The Tribunal interpreted the term "owns" in section 194C(6) to encompass possession rather than strict registered ownership. Referring to section 44AE, which defines "owner" for the purpose of presumptive taxation, the Tribunal concluded that ownership includes possession of the goods carriage, not just registered ownership. Citing judicial precedents and the intention of the legislature to provide benefits to taxpayers, the Tribunal determined that the appellant complied with section 194C(6) by obtaining declarations from those in possession of the goods carriages and making payments accordingly.
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