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of <h1>Tax Credit Capped at 100% for Section 201 Appeals Exceeding Disputed Tax Post-March 31, 2021, in Search Cases.</h1> In scenarios where the payment on settlement of a Section 201 appeal exceeds 100% of the disputed tax, either due to it being a search case or because payment is made after March 31, 2021, the tax credit available to the deductee is capped at 100% of the disputed tax. This holds true even if the deductor is required to pay more than 100% to settle the appeal.
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