Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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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