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...
The HC set aside the impugned order denying the petitioner a nil rate TDS certificate under section 197 for receipts classified as royalty. The court held that the AO erred in relying on a decision overruled by the SC and in disregarding the binding SC precedent under Article 141 of the Constitution due to a pending review petition. The HC ruled that the pendency of the review petition does not justify non-compliance with the SC judgment. The matter was remanded to the AO for fresh consideration of the petitioner's application in accordance with the binding SC decision, directing disposal within six weeks.
The HC set aside the impugned order denying the petitioner a nil rate TDS certificate under section 197 for receipts classified as royalty. The court held that the AO erred in relying on a decision overruled by the SC and in disregarding the binding SC precedent under Article 141 of the Constitution due to a pending review petition. The HC ruled that the pendency of the review petition does not justify non-compliance with the SC judgment. The matter was remanded to the AO for fresh consideration of the petitioner's application in accordance with the binding SC decision, directing disposal within six weeks.
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