Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Section 194-IA did not require aggregation of consideration attributable to multiple co-owners for the year in question, and the Finance Act, 2024 amendment was prospective and inapplicable. Because the amount relatable to each co-owner was below the statutory threshold, the purchaser had no obligation to deduct tax at source under section 194-IA. As no TDS default survived, the assessee could not be treated as an assessee in default under section 201(1), and the consequential interest under section 201(1A) was also unsustainable. The Tribunal followed coordinate bench rulings on the same issue and deleted the demand and interest.
Section 194-IA did not require aggregation of consideration attributable to multiple co-owners for the year in question, and the Finance Act, 2024 amendment was prospective and inapplicable. Because the amount relatable to each co-owner was below the statutory threshold, the purchaser had no obligation to deduct tax at source under section 194-IA. As no TDS default survived, the assessee could not be treated as an assessee in default under section 201(1), and the consequential interest under section 201(1A) was also unsustainable. The Tribunal followed coordinate bench rulings on the same issue and deleted the demand and interest.
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