Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Expenditure incurred by a head office for Indian operations was treated as potentially falling within the meaning of head office expenditure under the Explanation to section 44C, with the Tribunal remitting the matter for verification and directing that any deduction be restricted to the statutory formula if the provision applies. Payments described as reimbursements for technical support, supervision and related managerial services were held liable to withholding under section 195, so disallowance under section 40(a)(i) was sustained. The Article 26 non-discrimination plea under the India-USA DTAA failed because the withholding rule was based on residence and compliance, not nationality. The Tribunal also held that penalty initiation was premature.
Expenditure incurred by a head office for Indian operations was treated as potentially falling within the meaning of head office expenditure under the Explanation to section 44C, with the Tribunal remitting the matter for verification and directing that any deduction be restricted to the statutory formula if the provision applies. Payments described as reimbursements for technical support, supervision and related managerial services were held liable to withholding under section 195, so disallowance under section 40(a)(i) was sustained. The Article 26 non-discrimination plea under the India-USA DTAA failed because the withholding rule was based on residence and compliance, not nationality. The Tribunal also held that penalty initiation was premature.
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