Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
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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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