Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
TDS under section 194I applies to annual lease rent paid to a development authority, focusing on the scope of the term "rent" as the dominant issue; the present facts mirror prior authority and no substantial distinction was shown, so the authority of the earlier judgment requiring TDS on such payments was applied and the appeals were rejected. The prior decision was held to operate prospectively from its date, and its subsequent judicial affirmation was noted. The question left open by this decision remains available for later resolution.
TDS under section 194I applies to annual lease rent paid to a development authority, focusing on the scope of the term "rent" as the dominant issue; the present facts mirror prior authority and no substantial distinction was shown, so the authority of the earlier judgment requiring TDS on such payments was applied and the appeals were rejected. The prior decision was held to operate prospectively from its date, and its subsequent judicial affirmation was noted. The question left open by this decision remains available for later resolution.
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