Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
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Jurisdiction of the National Faceless Assessment Centre (NFAC) to change the "head" of Tax Deducted at Source (TDS) provision from "salary u/s 192" to "commission u/s 194A" in proceedings u/s 154 read with Section 200A. The assessee's contention is that Section 200A, being a complete code for processing TDS returns, overrides other general provisions, and the NFAC cannot change the head of TDS applicability once TDS has been deducted u/s 192 at the time of payment. The Tribunal accepted the assessee's arguments, concluding that the NFAC erred in law and on facts in raising the demand by changing the head from "salary" to "commission," and the demand was reversed.
Jurisdiction of the National Faceless Assessment Centre (NFAC) to change the "head" of Tax Deducted at Source (TDS) provision from "salary u/s 192" to "commission u/s 194A" in proceedings u/s 154 read with Section 200A. The assessee's contention is that Section 200A, being a complete code for processing TDS returns, overrides other general provisions, and the NFAC cannot change the head of TDS applicability once TDS has been deducted u/s 192 at the time of payment. The Tribunal accepted the assessee's arguments, concluding that the NFAC erred in law and on facts in raising the demand by changing the head from "salary" to "commission," and the demand was reversed.
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