When zero percentage is actually debited otherwise credited so you’re able to particular party’s account, following eg fee can’t be thought into the ambit of sec 194C or other TDS arrangements.
There’s no consistent measuring stick to help you measure brand new waste in almost any procedure for creation of products. Next wastage greeting of the assessee so you can goldsmith was an issue off company wisdom/commercial expediency and same can not be contacted so you can question of the AO except if he’s got evidence to show that the exact same was too-much.
Given that assessee have none debited and work out costs into P & L an effective/c nor credited people add up to parties’ account, the question off applying of sec 194C cannot develop.
While the no Independent proof could have been created record by AO to help with their results, because facing assessee which have produced requisite indications to prove you to definitely and also make costs could have been on their own paid and you can TDS deducted no matter where relevant, the latest introduction can’t be suffered.
S. 194-IA : TDS – Commission off Refundable Coverage Put by creator in order to Landowners of the advantage out of JDA – If or not Down-payment not connected with transfer away from immovable possessions accountable in order to TDS u/s 194-IA ? [Sec 201(1)]
S. 195 : TDS – Percentage so you’re able to non-resident overseas – Department Agreement – Principal and you may representative dating – Conversion process percentage to have functions made exterior India – Not secured you/s 195 [Sec
Assessee Organization, a developer, joined to your JDA sperm general strength regarding attorneys with landowners, which the new landowners wanted to import a fraction of belongings, in the place of display within the superstructure that’s to get created because of the designer. (more…)