Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Tribunal rejected the Assessing Officer's unexamined application of a higher withholding rate where the payer's case was that payees were unidentified, and held that applicability of the higher rate cannot be presumed without record support. The Tribunal remitted the disallowances under payroll withholding provisions for de novo verification of whether tax was in fact deducted and deposited under Chapter XVII-B, allowing the assessee to file supporting details. Separately, the Tribunal set aside denial of deduction for CSR payments and remitted the matter for AO verification of compliance with statutory conditions for charitable deductions under Chapter VIA.
Tribunal rejected the Assessing Officer's unexamined application of a higher withholding rate where the payer's case was that payees were unidentified, and held that applicability of the higher rate cannot be presumed without record support. The Tribunal remitted the disallowances under payroll withholding provisions for de novo verification of whether tax was in fact deducted and deposited under Chapter XVII-B, allowing the assessee to file supporting details. Separately, the Tribunal set aside denial of deduction for CSR payments and remitted the matter for AO verification of compliance with statutory conditions for charitable deductions under Chapter VIA.
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