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...
The article determines that the applicant institute qualifies as a specified person required to deduct TDS under Section 51 read with Notification No.50/2018 CT because substantial regulatory control (not day to day operational control) by the Central Government exists; Supreme Court precedent overrides administrative circulars. It clarifies that "control" denotes regulatory authority sufficient to trigger notification coverage. On contractual threshold, where supply is continuous and performed in parts, the contract as a whole-aggregating all part invoices-determines the threshold for TDS; separate contracts are assessed individually. Outcome: the institute is liable to deduct TDS.
The article determines that the applicant institute qualifies as a specified person required to deduct TDS under Section 51 read with Notification No.50/2018 CT because substantial regulatory control (not day to day operational control) by the Central Government exists; Supreme Court precedent overrides administrative circulars. It clarifies that "control" denotes regulatory authority sufficient to trigger notification coverage. On contractual threshold, where supply is continuous and performed in parts, the contract as a whole-aggregating all part invoices-determines the threshold for TDS; separate contracts are assessed individually. Outcome: the institute is liable to deduct TDS.
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