Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Tax deduction at source (TDS) u/s 194IA is applicable on the payment made for purchase of immovable property, not on the stamp duty valuation. The provision mandating TDS on stamp duty value was introduced from April 1, 2022, after the assessee's transaction. Since the assessee was not liable to deduct TDS u/s 194IA at the time of transaction, the penalty u/s 234E for late filing of TDS return is cancelled. The appeal against the penalty is allowed, as the assessee was not obligated to deduct TDS on the transaction value.
Tax deduction at source (TDS) u/s 194IA is applicable on the payment made for purchase of immovable property, not on the stamp duty valuation. The provision mandating TDS on stamp duty value was introduced from April 1, 2022, after the assessee's transaction. Since the assessee was not liable to deduct TDS u/s 194IA at the time of transaction, the penalty u/s 234E for late filing of TDS return is cancelled. The appeal against the penalty is allowed, as the assessee was not obligated to deduct TDS on the transaction value.
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