Revenue's review petitions dismissed; earlier rulings protected assessee on TDS under s.195 and disallowance under s.40(a)(i) HC dismissed the revenue's review petitions challenging orders that had upheld the assessee on issues of TDS under s.195 and disallowance under s.40(a)(i) ...
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Revenue's review petitions dismissed; earlier rulings protected assessee on TDS under s.195 and disallowance under s.40(a)(i)
HC dismissed the revenue's review petitions challenging orders that had upheld the assessee on issues of TDS under s.195 and disallowance under s.40(a)(i) in respect of payments (reimbursements of salary and other expenditures) to a foreign entity. The court held earlier substantial questions were decided in the assessee's favour by prior HC judgments, the review petitions against those orders were dismissed, and therefore the impugned orders require no interference; review petitions stand dismissed.
ITAs No. 420/2015 and 421/2015 were disposed on the Revenue's concession that the "substantial questions raised therein were answered in favour of the assessee by judgment dated 01.12.2020" in ITAs No. 214/2014 & 215/2014. The Revenue thereafter filed review petitions No. 9/2021 and 10/2021 against the 01.12.2020 orders; those review petitions were dismissed. Because the review petitions against the earlier orders have been dismissed, the order dated 06.07.2021 in ITAs No. 420/2015 and 421/2015 requires no interference. Consequently, the review petitions are dismissed. No costs.
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