Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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