Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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TDS u/s 194H - Higher rate of TDS @20% in absence of PAN - Commission paid to Primary Agriculture Cooperative Society (PACS) - The Tribunal examined the nature of transactions between the appellant and PACS. It found that the State Government, through its nodal agencies, controlled and directed the activities of PACS in procuring food grains, indicating an agency relationship. Consequently, the commission paid by the appellant to PACS was deemed liable for TDS under Section 194H. It also observed errors in the calculation of TDS, considering that PACS likely had PAN details and that the commission rate was not accurately applied.
TDS u/s 194H - Higher rate of TDS @20% in absence of PAN - Commission paid to Primary Agriculture Cooperative Society (PACS) - The Tribunal examined the nature of transactions between the appellant and PACS. It found that the State Government, through its nodal agencies, controlled and directed the activities of PACS in procuring food grains, indicating an agency relationship. Consequently, the commission paid by the appellant to PACS was deemed liable for TDS under Section 194H. It also observed errors in the calculation of TDS, considering that PACS likely had PAN details and that the commission rate was not accurately applied.
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