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...
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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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