Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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The case involved a dispute over short collection of TDS due to lower TDS certificates with different TANs issued by deductees. The Central Processing Centre (CPC) raised a demand for tax and interest, but the CIT(A) emphasized the duty of the assessee to inform suppliers about the new TAN and request revised certificates. The Tribunal held that the assessee, as the person responsible for TDS, complied with certificates issued u/s. 197 by deducting tax at source as per rates specified. The genuineness of the certificates was not in question. The procedure for obtaining lower rate deduction certificates under Rule 28(AA) was noted, emphasizing that certificates are valid for the named person responsible for deduction. The Tribunal, citing legal provisions and precedent, ruled in favor of the assessee, concluding no short deduction of tax occurred, and deleted the demand for tax and interest.
The case involved a dispute over short collection of TDS due to lower TDS certificates with different TANs issued by deductees. The Central Processing Centre (CPC) raised a demand for tax and interest, but the CIT(A) emphasized the duty of the assessee to inform suppliers about the new TAN and request revised certificates. The Tribunal held that the assessee, as the person responsible for TDS, complied with certificates issued u/s. 197 by deducting tax at source as per rates specified. The genuineness of the certificates was not in question. The procedure for obtaining lower rate deduction certificates under Rule 28(AA) was noted, emphasizing that certificates are valid for the named person responsible for deduction. The Tribunal, citing legal provisions and precedent, ruled in favor of the assessee, concluding no short deduction of tax occurred, and deleted the demand for tax and interest.
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