Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The High Court dismissed the appeals filed by the Revenue as withdrawn, holding that the appeals did not fall under the exception carved out in Circular No. 3.1(l) dated 15.03.2024. The Court ruled that the exception in Clause 3.1(l) applies only to cases where the deductor failed to deduct tax at source and the tax was sought to be recovered from the payer. However, in the present case, the issue pertained to the disallowance of expenses claimed by the assessee due to non-deduction of tax at source u/s 195. The Court clarified that litigation arising from regular assessments u/s 143(3) and failure to deduct tax at source are treated separately under the Act. Consequently, the enhanced monetary limits specified in the Circular applied retrospectively, rendering the tax effect in the appeals below the prescribed threshold, leading to their dismissal.
The High Court dismissed the appeals filed by the Revenue as withdrawn, holding that the appeals did not fall under the exception carved out in Circular No. 3.1(l) dated 15.03.2024. The Court ruled that the exception in Clause 3.1(l) applies only to cases where the deductor failed to deduct tax at source and the tax was sought to be recovered from the payer. However, in the present case, the issue pertained to the disallowance of expenses claimed by the assessee due to non-deduction of tax at source u/s 195. The Court clarified that litigation arising from regular assessments u/s 143(3) and failure to deduct tax at source are treated separately under the Act. Consequently, the enhanced monetary limits specified in the Circular applied retrospectively, rendering the tax effect in the appeals below the prescribed threshold, leading to their dismissal.
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