Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
A certificate issued under the withholding regime is effective for the entire assessment year specified, not only prospectively from its issuance; construing the statutory provisions and Rule 28AA(2), the certificate remains operative throughout that assessment year unless earlier cancelled. Applying that rule, a deductor who relied on a valid certificate for the assessment year cannot be treated as an assessee in default for lower deduction, and consequential interest charged on that basis is not leviable where the certificate stood in force and was not cancelled.
A certificate issued under the withholding regime is effective for the entire assessment year specified, not only prospectively from its issuance; construing the statutory provisions and Rule 28AA(2), the certificate remains operative throughout that assessment year unless earlier cancelled. Applying that rule, a deductor who relied on a valid certificate for the assessment year cannot be treated as an assessee in default for lower deduction, and consequential interest charged on that basis is not leviable where the certificate stood in force and was not cancelled.
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