Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Dispute concerns entitlement to TDS credit where the assessee acted as a Kaccha Arhtia (commission agent). Tribunal accepted that amounts received by traders on behalf of farmers were not the assessees revenue, while commission receipts constituted the assessees income; TDS deducted from payments that were the assessees money must be allowed as credit. The tribunal directed the assessing officer to grant full TDS credit to the assessee, noting the nature of receipts rather than specific provisions under which TDS was deducted.
Dispute concerns entitlement to TDS credit where the assessee acted as a Kaccha Arhtia (commission agent). Tribunal accepted that amounts received by traders on behalf of farmers were not the assessees revenue, while commission receipts constituted the assessees income; TDS deducted from payments that were the assessees money must be allowed as credit. The tribunal directed the assessing officer to grant full TDS credit to the assessee, noting the nature of receipts rather than specific provisions under which TDS was deducted.
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