Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
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...
Discussions address TDS obligations for rental and professional service payments where failure to deduct on provision led to assessment under withholding liability. For rent, absence of recipient declarations or proof of taxability and no evidence of payment despite provision, combined with a bank assessees access to expert advice, meant the proviso conditions were not satisfied and withholding liability was upheld, resulting in default treatment. For legal and consultation fees, part payment on which TDS was shown to be deducted may relieve the assessee for that portion; the remainder is remitted to the TDS assessing officer for verification and adjustment. Appeal partly allowed accordingly.
Discussions address TDS obligations for rental and professional service payments where failure to deduct on provision led to assessment under withholding liability. For rent, absence of recipient declarations or proof of taxability and no evidence of payment despite provision, combined with a bank assessees access to expert advice, meant the proviso conditions were not satisfied and withholding liability was upheld, resulting in default treatment. For legal and consultation fees, part payment on which TDS was shown to be deducted may relieve the assessee for that portion; the remainder is remitted to the TDS assessing officer for verification and adjustment. Appeal partly allowed accordingly.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
