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...
TDS u/s 194C, not 194I, is applicable on payment of Common Area Maintenance (CAM) charges. CAM charges paid by the assessee do not form part of actual rent paid to the owner, but are for separate and distinguishable services. CAM charges cannot be said to be for use of building. Therefore, the correct TDS provision applicable is Section 194C at 2%, not Section 194I. The assessee was in default u/s 201(1) for short deduction of TDS. The issue is covered by a series of ITAT decisions, including Connaught Plaza Restaurants P. Ltd, holding that CAM charges are liable for TDS u/s 194C, not 194I. The appeal of the assessee is allowed.
TDS u/s 194C, not 194I, is applicable on payment of Common Area Maintenance (CAM) charges. CAM charges paid by the assessee do not form part of actual rent paid to the owner, but are for separate and distinguishable services. CAM charges cannot be said to be for use of building. Therefore, the correct TDS provision applicable is Section 194C at 2%, not Section 194I. The assessee was in default u/s 201(1) for short deduction of TDS. The issue is covered by a series of ITAT decisions, including Connaught Plaza Restaurants P. Ltd, holding that CAM charges are liable for TDS u/s 194C, not 194I. The appeal of the assessee is allowed.
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