Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The case involves TDS issues u/s 194A, 194H, and 194J concerning surplus interest retained by NBFCs. The assessee, a bank, purchased loans from NBFCs with a tripartite agreement allowing NBFCs to retain part interest. The tribunal held that the retained interest does not qualify as "interest" u/s 194A as the assessee did not borrow funds from NBFCs. Similarly, no TDS is required u/s 194H as NBFCs did not act on behalf of the assessee. Regarding u/s 194J, the consideration for loan assignment includes upfront payment and lower interest, not subject to TDS. Tax u/s 201(1) and interest u/s 201(1A) are not applicable as NBFCs already paid tax on interest earned. Decision favors the assessee.
The case involves TDS issues u/s 194A, 194H, and 194J concerning surplus interest retained by NBFCs. The assessee, a bank, purchased loans from NBFCs with a tripartite agreement allowing NBFCs to retain part interest. The tribunal held that the retained interest does not qualify as "interest" u/s 194A as the assessee did not borrow funds from NBFCs. Similarly, no TDS is required u/s 194H as NBFCs did not act on behalf of the assessee. Regarding u/s 194J, the consideration for loan assignment includes upfront payment and lower interest, not subject to TDS. Tax u/s 201(1) and interest u/s 201(1A) are not applicable as NBFCs already paid tax on interest earned. Decision favors the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
