S. 207 : Advance tax-Salary income-Tax deducted at source-Not liable to pay advance tax. [S. 143(1), 192, 207(2), 208, 234B, 234C]
S. 207 : Advance tax-Salary income-Tax deducted at source-Not liable to pay advance tax. [S. 143(1), 192, 207(2), 208, 234B, 234C]
S. 201 : Deduction at source-Failure to deduct or pay-Deducted at the time of payment Amounts not deductible-Deduction at source-Non-resident-Once an amount is disallowed for non-deduction of tax, it cannot be subject to TDS provisions again so as to make assessee liable to interest under section 201(1A) of the Act. [S. 40(ia), 40(a)(ia), 201(1), 201(IA)]
S. 201 : Deduction at source-Failure to deduct or pay-Deducted at the time of payment-Deposited subsequent year-Assessee cannot be treated as assessee in default. [S. 201(1), 201(IA)]
S. 201 : Deduction at source-Failure to deduct or pay-Survey-Rural bank-Non submission of Form 15G and Form 15H-Collected more than 75 percent of Forms-Order levying interest is set aside. [S. 133A, 197A, 201, 201(IA), Form No 15G, 15H, Regional Rural Banks Act]
S. 195 : Deduction at source-Non-resident-Right to use software-Not royalty-Not liable to deduct tax at source. [S. 9(1)(vi), Copy Right Act, 1957, S. 14(b)]
S. 149 : Reassessment-Time limit for notice-Amendment to section 149(1), introduced with effect from 1-4-2012, providing longer time limit of 16 years for reopening assessments in foreign asset cases is expressly stated to be retrospective in nature. [S. 143(3), 147, 149(1)(c)]
S. 147 : Reassessment-Income deemed to accrue or arise in India-Permanent Establishment-Notice based on the assessment orders of earlier years orders is held to be not valid. [S. 9(1)(i), 148]
S. 144C : Reference to dispute resolution panel-Order passed without following the directions of DRP-Order was set aside. [S. 92C 144C(5)]
S. 144C : Reference to dispute resolution panel-Failure to pass draft assessment order-Violation of procedure-Order set aside. [S. 144C(13), 271(1)(c)]
S. 92C : Transfer pricing-Arm’s length price-Comparable-Distribution of products-Royalty paid by assessee would be within arm length range and impugned ALP adjustments were deleted-Merchandise and samples from its AE for resale in India-Resale Price Method (RPM) is Most Appropriate Method (MAM) to benchmark said international transaction.