Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The High Court quashed the impugned orders, holding that Section 206AA, mandating 20% TDS rate for invalid PAN, was not applicable. The vendor had linked his PAN with Aadhaar by paying late fee, rendering his PAN valid. The petitioners remitted payment against vendor's valid PAN and filed Form 26QB mentioning the same. The departmental website accepted the filing without indicating PAN invalidity. Thus, deducting TDS at 20% rate by deeming vendor's PAN invalid was contrary to facts and violated natural justice principles.
The High Court quashed the impugned orders, holding that Section 206AA, mandating 20% TDS rate for invalid PAN, was not applicable. The vendor had linked his PAN with Aadhaar by paying late fee, rendering his PAN valid. The petitioners remitted payment against vendor's valid PAN and filed Form 26QB mentioning the same. The departmental website accepted the filing without indicating PAN invalidity. Thus, deducting TDS at 20% rate by deeming vendor's PAN invalid was contrary to facts and violated natural justice principles.
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