Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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The ITAT ruled in favor of the appellant, allowing credit for TDS deducted under Section 194C. The Tribunal determined that despite transferring gross contract receipts to constituent partners on a back-to-back basis, the appellant properly reported the profit/loss in its own returns. The AO erroneously invoked Section 238(1) to deny TDS credit, overlooking that the appellant had disclosed relevant profits and claimed corresponding TDS in accordance with Section 199(1) and Rule 37BA(1). Since payments were made to the appellant and TDS was remitted to the government in the appellant's name as evidenced by Form 26AS, the appellant alone was entitled to claim the TDS credit.
The ITAT ruled in favor of the appellant, allowing credit for TDS deducted under Section 194C. The Tribunal determined that despite transferring gross contract receipts to constituent partners on a back-to-back basis, the appellant properly reported the profit/loss in its own returns. The AO erroneously invoked Section 238(1) to deny TDS credit, overlooking that the appellant had disclosed relevant profits and claimed corresponding TDS in accordance with Section 199(1) and Rule 37BA(1). Since payments were made to the appellant and TDS was remitted to the government in the appellant's name as evidenced by Form 26AS, the appellant alone was entitled to claim the TDS credit.
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