Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
The ITAT examined two issues: (1) Tax deduction at source (TDS) u/s 195 on payments to seconded employees, and (2) disallowance of technology fees paid to the parent company. Regarding TDS, the ITAT found clauses indicating the seconded employees had a lien on their jobs with the parent company, and the assessee provided tools/equipment and indemnified the parent company. These aspects required fresh examination by the Assessing Officer (AO) to determine the true nature of payments. On technology fees disallowance, the ITAT held that the AO/TPO cannot disallow genuine expenses merely because no benefits accrued. However, the assessee failed to substantiate services rendered by the parent company through cogent evidence. The ITAT remitted this issue to the AO/TPO for fresh adjudication after considering all evidence filed. The assessee's appeal was allowed for statistical purposes.
The ITAT examined two issues: (1) Tax deduction at source (TDS) u/s 195 on payments to seconded employees, and (2) disallowance of technology fees paid to the parent company. Regarding TDS, the ITAT found clauses indicating the seconded employees had a lien on their jobs with the parent company, and the assessee provided tools/equipment and indemnified the parent company. These aspects required fresh examination by the Assessing Officer (AO) to determine the true nature of payments. On technology fees disallowance, the ITAT held that the AO/TPO cannot disallow genuine expenses merely because no benefits accrued. However, the assessee failed to substantiate services rendered by the parent company through cogent evidence. The ITAT remitted this issue to the AO/TPO for fresh adjudication after considering all evidence filed. The assessee's appeal was allowed for statistical purposes.
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