Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
TDS u/s 194C - payments of purchase to various vendors - Non deduction of TDS - Upon analysis, the Appellate Tribunal agreed with the assessee, ruling that the transactions were indeed purchases of finished goods. It noted that the manufacturers independently sourced raw materials and produced goods according to the specifications provided. Furthermore, the Tribunal found that the assessee's control over production was limited, as evidenced by the return of rejected goods to the vendors. Tribunal dismissed the revenue's appeal.
TDS u/s 194C - payments of purchase to various vendors - Non deduction of TDS - Upon analysis, the Appellate Tribunal agreed with the assessee, ruling that the transactions were indeed purchases of finished goods. It noted that the manufacturers independently sourced raw materials and produced goods according to the specifications provided. Furthermore, the Tribunal found that the assessee's control over production was limited, as evidenced by the return of rejected goods to the vendors. Tribunal dismissed the revenue's appeal.
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