Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
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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