Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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The ITAT Delhi ruled on TDS u/s 194H and 194J regarding income/profit component in payments to distributors/franchisees. The payment cannot be treated as commission or brokerage. Citing Bharti Cellular Ltd. case, it held no legal obligation for TDS on such payments. Section 194-H deemed inapplicable, leading to setting aside of the demand u/s 201(1)/201(1A). Appellant's appeal allowed based on established legal principles.
The ITAT Delhi ruled on TDS u/s 194H and 194J regarding income/profit component in payments to distributors/franchisees. The payment cannot be treated as commission or brokerage. Citing Bharti Cellular Ltd. case, it held no legal obligation for TDS on such payments. Section 194-H deemed inapplicable, leading to setting aside of the demand u/s 201(1)/201(1A). Appellant's appeal allowed based on established legal principles.
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