Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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