Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT allowed the appeal of the assessee and set aside the orders of the lower authorities, holding that provisions of section 194H read with sections 201 and 201(1A) were not attracted for AY 2015-16. The Tribunal found no principal-agent relationship between the assessee and the payment gateway operators (CC Avenues and Zaaki payment services), treated the transactions as outside the scope of commission liable to TDS, and relied on relevant judicial precedent and CBDT instruction. The Tribunal directed the AO to delete the impugned demand under sections 201 and 201(1A) and allowed all grounds of appeal raised by the assessee.
ITAT allowed the appeal of the assessee and set aside the orders of the lower authorities, holding that provisions of section 194H read with sections 201 and 201(1A) were not attracted for AY 2015-16. The Tribunal found no principal-agent relationship between the assessee and the payment gateway operators (CC Avenues and Zaaki payment services), treated the transactions as outside the scope of commission liable to TDS, and relied on relevant judicial precedent and CBDT instruction. The Tribunal directed the AO to delete the impugned demand under sections 201 and 201(1A) and allowed all grounds of appeal raised by the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
