Condonation of Delay: Tribunal directed condonation where rectification proceedings were pursued, ordering merits adjudication after opportunity to be...
Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Page of 4816
Press 'Enter' after typing page number.
5461 to 5480 of 96301 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Payments to a non-resident under a Production Sharing Contract were treated as taxable unless the claimed reimbursement was supported by item-wise expenditure particulars and, where necessary, a chargeable proportion determination under the withholding regime. The arm's length clause did not create a presumption that every reimbursement was non-taxable. Because the assessee had filed only a consolidated reimbursement claim without furnishing details or seeking determination of the chargeable portion, tax at source was required and liability under the deeming provisions was upheld. The alternative double taxation relief argument failed because, for the relevant years, relief applied only to agreements with foreign Governments, not the private consortium arrangement.
Payments to a non-resident under a Production Sharing Contract were treated as taxable unless the claimed reimbursement was supported by item-wise expenditure particulars and, where necessary, a chargeable proportion determination under the withholding regime. The arm's length clause did not create a presumption that every reimbursement was non-taxable. Because the assessee had filed only a consolidated reimbursement claim without furnishing details or seeking determination of the chargeable portion, tax at source was required and liability under the deeming provisions was upheld. The alternative double taxation relief argument failed because, for the relevant years, relief applied only to agreements with foreign Governments, not the private consortium arrangement.
Note: It is a system-generated summary and is for quick reference only.