Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The Appellate Tribunal addressed two issues regarding TDS credit. Firstly, the Tribunal emphasized that income and TDS must align in any assessment year when income is accrued to the assessee. Therefore, TDS credit cannot be isolated without corresponding income for taxation. The matter was remitted to the Assessing Officer for reconsideration. Secondly, the Tribunal clarified that TDS credit should be available in the year the income is reported, as per Section 199(3) and Rule 37BA(3). The Tribunal directed that the assessee is entitled to TDS credit in the Assessment Year 2017-18 if certain conditions are met, ensuring no double claiming of credit. The decision of the CIT(A) was set aside, and the case was sent back to the Assessing Officer for granting TDS credit in the specified assessment year.
The Appellate Tribunal addressed two issues regarding TDS credit. Firstly, the Tribunal emphasized that income and TDS must align in any assessment year when income is accrued to the assessee. Therefore, TDS credit cannot be isolated without corresponding income for taxation. The matter was remitted to the Assessing Officer for reconsideration. Secondly, the Tribunal clarified that TDS credit should be available in the year the income is reported, as per Section 199(3) and Rule 37BA(3). The Tribunal directed that the assessee is entitled to TDS credit in the Assessment Year 2017-18 if certain conditions are met, ensuring no double claiming of credit. The decision of the CIT(A) was set aside, and the case was sent back to the Assessing Officer for granting TDS credit in the specified assessment year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
