Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
TDS credit cannot be denied in scrutiny assessment where the Revenue had already rectified the earlier intimation and granted the credit, leaving no surviving dispute on the same claim. The Tribunal held that the Assessing Officer overlooked the rectification order and that, in the absence of any asserted mismatch, deficiency in the claim, or failure to offer the corresponding income, the assessee remained entitled to the tax credit actually prepaid by TDS. The consequential interest levied under sections 234A and 234B was therefore deleted.
TDS credit cannot be denied in scrutiny assessment where the Revenue had already rectified the earlier intimation and granted the credit, leaving no surviving dispute on the same claim. The Tribunal held that the Assessing Officer overlooked the rectification order and that, in the absence of any asserted mismatch, deficiency in the claim, or failure to offer the corresponding income, the assessee remained entitled to the tax credit actually prepaid by TDS. The consequential interest levied under sections 234A and 234B was therefore deleted.
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