Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
ITAT held that payments made by the assessee to an unnamed service provider for composing and DTP of manuscripts constitute contract work falling within the scope of section 194C and do not amount to technical or professional fees under the explanation to section 194J. Consequently, the assessee's deduction of tax at source at 2% from contractual payments was held to be correct. The Tribunal directed the Assessing Officer to delete the demand raised for alleged short deduction under section 194J and allowed the assessee's appeal, thereby dismissing the revenue's contention and removing the resultant tax demand.
ITAT held that payments made by the assessee to an unnamed service provider for composing and DTP of manuscripts constitute contract work falling within the scope of section 194C and do not amount to technical or professional fees under the explanation to section 194J. Consequently, the assessee's deduction of tax at source at 2% from contractual payments was held to be correct. The Tribunal directed the Assessing Officer to delete the demand raised for alleged short deduction under section 194J and allowed the assessee's appeal, thereby dismissing the revenue's contention and removing the resultant tax demand.
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