https://www.taxtmi.com/caselaws?id=387582 Payments to affiliates could not be finally treated as reimbursement outside TDS under section 194C on the existing record because the true character of the remittances had not been properly examined. The Tribunal noted that the Assessing Officer and the first appellate authority had not sufficiently verified whether the liability had actually crystallised, whether the payment was only a square-off of an existing liability, or whether any profit element was embedded, and the supporting documents were incomplete. The order of the first appellate authority was therefore set aside and the matter was restored for de novo adjudication after giving the assessee a reasonable opportunity of being heard. en-us Mon, 07 Oct 2019 00:00:00 +0530 Fri, 08 Nov 2024 11:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=387582 Payments to affiliates could not be finally treated as reimbursement outside TDS under section 194C on the existing record because the true character of the remittances had not been properly examined. The Tribunal noted that the Assessing Officer and the first appellate authority had not sufficiently verified whether the liability had actually crystallised, whether the payment was only a square-off of an existing liability, or whether any profit element was embedded, and the supporting documents were incomplete. The order of the first appellate authority was therefore set aside and the matter was restored for de novo adjudication after giving the assessee a reasonable opportunity of being heard. Case-Laws Income Tax Mon, 07 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=387582