Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
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...
The ITAT, an Appellate Tribunal, addressed the issue of TDS u/s 194A. The case involved delay interest charged by a broker, treated as finance cost, without TDS deduction. ITAT held that interest paid for delayed payments, not on borrowed capital, isn't covered u/s 2(28A). Citing a similar case, ITAT directed AO to delete the addition, allowing the assessee's appeal. The decision clarified that Section 194A applies to interest on borrowed capital, not on delayed purchase payments.
The ITAT, an Appellate Tribunal, addressed the issue of TDS u/s 194A. The case involved delay interest charged by a broker, treated as finance cost, without TDS deduction. ITAT held that interest paid for delayed payments, not on borrowed capital, isn't covered u/s 2(28A). Citing a similar case, ITAT directed AO to delete the addition, allowing the assessee's appeal. The decision clarified that Section 194A applies to interest on borrowed capital, not on delayed purchase payments.
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