Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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The assessee, a licensed commission agent in the Agricultural Market Committee Yard, Guntur, claimed credit for the entire amount deducted as tax at source u/s 194Q from commission income, which was deducted as tax at source u/s 194A from interest income. The assessee relied on CBDT Circular No. 452 and the case of Yagneswari General Traders, stating that the turnover of Kaccha Arahtias includes only the gross commission and not the sales effected on behalf of principals. The ITAT held that since the assessee acted as an agent (Kaccha Arahtia), the CBDT Circular applied, and the assessee was eligible to get credit for the entire amount deducted as tax at source. Consequently, there was no shortfall of TDS as concluded by the Revenue Authorities, and the assessee's appeal was allowed.
The assessee, a licensed commission agent in the Agricultural Market Committee Yard, Guntur, claimed credit for the entire amount deducted as tax at source u/s 194Q from commission income, which was deducted as tax at source u/s 194A from interest income. The assessee relied on CBDT Circular No. 452 and the case of Yagneswari General Traders, stating that the turnover of Kaccha Arahtias includes only the gross commission and not the sales effected on behalf of principals. The ITAT held that since the assessee acted as an agent (Kaccha Arahtia), the CBDT Circular applied, and the assessee was eligible to get credit for the entire amount deducted as tax at source. Consequently, there was no shortfall of TDS as concluded by the Revenue Authorities, and the assessee's appeal was allowed.
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