Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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