Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Credit for TDS reflected as deducted from the employee's income was denied solely because the employer failed to deposit the tax with the Central Government account. Applying the principle that an assessee cannot be prejudiced for the deductor's default where deduction is evidenced, the authority was directed to grant the TDS credit to the employee. Any recovery or adjustment already effected on account of the consequent demand was ordered to be refunded with statutory interest within eight weeks. - HC
Credit for TDS reflected as deducted from the employee's income was denied solely because the employer failed to deposit the tax with the Central Government account. Applying the principle that an assessee cannot be prejudiced for the deductor's default where deduction is evidenced, the authority was directed to grant the TDS credit to the employee. Any recovery or adjustment already effected on account of the consequent demand was ordered to be refunded with statutory interest within eight weeks. - HC
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