Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Withholding tax on payments to non-residents arises only where the sum is chargeable to tax in India. The note states that commission and allied payments were made outside India to non-resident recipients for services rendered outside India, with no permanent establishment or business connection in India. The view that commission became taxable merely because the order was executed in India was rejected, and there was no material to treat the payments as fees for technical services. As no income accrued or arose in India, tax deduction at source was not required and disallowance for non-deduction was not warranted; the deletion of the disallowance was upheld.
Withholding tax on payments to non-residents arises only where the sum is chargeable to tax in India. The note states that commission and allied payments were made outside India to non-resident recipients for services rendered outside India, with no permanent establishment or business connection in India. The view that commission became taxable merely because the order was executed in India was rejected, and there was no material to treat the payments as fees for technical services. As no income accrued or arose in India, tax deduction at source was not required and disallowance for non-deduction was not warranted; the deletion of the disallowance was upheld.
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