Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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.
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