Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
CPC had restricted TDS credit to proportionate amounts on the basis that gross receipts shown in Form 26AS were not fully offered to tax; the note clarifies that where a taxpayer acts as an intermediary receiving payments on behalf of principals and recognises only commission as revenue, the residual receipts are not revenue of the intermediary and TDS deducted on those payments effectively pertains to the intermediary's receipts. Consequently, full credit of TDS reflected in Form 26AS should be allowed to the intermediary; CPC is directed to grant such full credit.
CPC had restricted TDS credit to proportionate amounts on the basis that gross receipts shown in Form 26AS were not fully offered to tax; the note clarifies that where a taxpayer acts as an intermediary receiving payments on behalf of principals and recognises only commission as revenue, the residual receipts are not revenue of the intermediary and TDS deducted on those payments effectively pertains to the intermediary's receipts. Consequently, full credit of TDS reflected in Form 26AS should be allowed to the intermediary; CPC is directed to grant such full credit.
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