Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Tax deducted at source (TDS) credit was denied in the intimation u/s 143(1) to the assessee. The Commissioner of Income Tax (Appeals) upheld the Centralized Processing Centre's action of restricting TDS credit to the extent relating to receipts reflected in the return for the impugned assessment year, in line with Section 199 and Rule 37BA. The assessee failed to demonstrate any infirmity in the CIT(A)'s findings regarding the interpretation of law on TDS credit and the fact that TDS was deducted on a portion of income already returned in preceding years. While upholding the CIT(A)'s order confirming the adjustment restricting TDS credit to Rs. 4,07,968/- against Rs. 5,24,600/- claimed, the Appellate Tribunal directed the Assessing Officer to give necessary TDS credit for income returned in the preceding two assessment years, as the gross receipts of Rs. 5,24,60,000/- included receipts already taxed in those years.
Tax deducted at source (TDS) credit was denied in the intimation u/s 143(1) to the assessee. The Commissioner of Income Tax (Appeals) upheld the Centralized Processing Centre's action of restricting TDS credit to the extent relating to receipts reflected in the return for the impugned assessment year, in line with Section 199 and Rule 37BA. The assessee failed to demonstrate any infirmity in the CIT(A)'s findings regarding the interpretation of law on TDS credit and the fact that TDS was deducted on a portion of income already returned in preceding years. While upholding the CIT(A)'s order confirming the adjustment restricting TDS credit to Rs. 4,07,968/- against Rs. 5,24,600/- claimed, the Appellate Tribunal directed the Assessing Officer to give necessary TDS credit for income returned in the preceding two assessment years, as the gross receipts of Rs. 5,24,60,000/- included receipts already taxed in those years.
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