Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Binding interim judicial directions governed the treatment of leave travel concession payments during the relevant period, so the assessee was obliged to follow those directions and could not be treated as disobeying the TDS requirement under a stand-alone reading of the statute. As the Tribunal held that failure to deduct tax in those circumstances did not constitute default under section 201(1), the consequential interest under section 201(1A) also could not survive. The demand and interest were therefore deleted, and the appeals were allowed.
Binding interim judicial directions governed the treatment of leave travel concession payments during the relevant period, so the assessee was obliged to follow those directions and could not be treated as disobeying the TDS requirement under a stand-alone reading of the statute. As the Tribunal held that failure to deduct tax in those circumstances did not constitute default under section 201(1), the consequential interest under section 201(1A) also could not survive. The demand and interest were therefore deleted, and the appeals were allowed.
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