Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
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.
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