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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Procedural lapses by third parties should not deprive taxpayers of TDS credit when they have acted in good faith and declared income. Section 205 bars direct tax recovery from deductees if tax was deducted, protecting them from double taxation. Rule 37BA aims to align TDS credit with income's beneficial owner. Denying credit due to third-party errors contradicts this purpose when the assessee rightfully owned and offered the income. Allowing TDS credit avoids revenue loss when tax was deducted and income declared. Substance should prevail over procedural deficiencies not attributable to the taxpayer. Denial of TDS credit solely on procedural grounds is unjustified.
Procedural lapses by third parties should not deprive taxpayers of TDS credit when they have acted in good faith and declared income. Section 205 bars direct tax recovery from deductees if tax was deducted, protecting them from double taxation. Rule 37BA aims to align TDS credit with income's beneficial owner. Denying credit due to third-party errors contradicts this purpose when the assessee rightfully owned and offered the income. Allowing TDS credit avoids revenue loss when tax was deducted and income declared. Substance should prevail over procedural deficiencies not attributable to the taxpayer. Denial of TDS credit solely on procedural grounds is unjustified.
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