Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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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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