Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Deduction of tax at source was required on the full stated consideration for purchase of immovable property under section 194IA; treating only part of the payment as outside the statutory base did not displace the obligation, so the section 201 default finding was sustained for the balance land consideration. For the other TDS disallowances relating to provisions and expenses, the Tribunal found that additional evidence, including Form 16A and a statement of items where tax was allegedly deducted and remitted, required factual verification. Those items were remitted to the Assessing Officer for de novo examination with liberty to file further evidence, and the matter was left open on the default question.
Deduction of tax at source was required on the full stated consideration for purchase of immovable property under section 194IA; treating only part of the payment as outside the statutory base did not displace the obligation, so the section 201 default finding was sustained for the balance land consideration. For the other TDS disallowances relating to provisions and expenses, the Tribunal found that additional evidence, including Form 16A and a statement of items where tax was allegedly deducted and remitted, required factual verification. Those items were remitted to the Assessing Officer for de novo examination with liberty to file further evidence, and the matter was left open on the default question.
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