Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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Section 194G applies only where income by way of commission, remuneration or prize is paid or credited to the payee, and a mere margin on resale does not constitute such payment. A reduced-price onward sale of lottery tickets to dealers on a principal-to-principal basis was treated as a discounted sale, not commission, because no amount was paid or credited by the assessee to the dealers. Section 194G was therefore inapplicable, TDS was not required, and the consequential proceedings under sections 201(1) and 201(1A) were unsustainable.
Section 194G applies only where income by way of commission, remuneration or prize is paid or credited to the payee, and a mere margin on resale does not constitute such payment. A reduced-price onward sale of lottery tickets to dealers on a principal-to-principal basis was treated as a discounted sale, not commission, because no amount was paid or credited by the assessee to the dealers. Section 194G was therefore inapplicable, TDS was not required, and the consequential proceedings under sections 201(1) and 201(1A) were unsustainable.
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