Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
TDS u/s 194H - non deduction of TDS commission paid to Primary Agriculture Co-operative Society (PACS) The Tribunal analyzed guidelines issued by the State Government and concluded that PACS functioned as agents of the State Government. Therefore, the commission paid by the assessee to PACS was subject to deduction of tax at source under section 194H of the Act. It was observed that the assessing officer had calculated TDS at the maximum rate without considering relevant factors such as the availability of PAN for PACS. Hence, the matter was remanded back to the assessing officer for proper verification and calculation of TDS.
TDS u/s 194H - non deduction of TDS commission paid to Primary Agriculture Co-operative Society (PACS) The Tribunal analyzed guidelines issued by the State Government and concluded that PACS functioned as agents of the State Government. Therefore, the commission paid by the assessee to PACS was subject to deduction of tax at source under section 194H of the Act. It was observed that the assessing officer had calculated TDS at the maximum rate without considering relevant factors such as the availability of PAN for PACS. Hence, the matter was remanded back to the assessing officer for proper verification and calculation of TDS.
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