Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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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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