Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
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Reinsurance premium remitted to non-resident reinsurers was not shown to be taxable in India either through a permanent establishment in India or as fees for technical services or royalty, so no tax was required to be withheld at source. The Tribunal noted that the Indian subsidiary was not the foreign reinsurer's PE for the relevant payments, and there was no material showing that technical, consultancy or similar services were rendered. The demand under section 201(1) and interest under section 201(1A) were therefore deleted, and the Revenue's appeal was dismissed.
Reinsurance premium remitted to non-resident reinsurers was not shown to be taxable in India either through a permanent establishment in India or as fees for technical services or royalty, so no tax was required to be withheld at source. The Tribunal noted that the Indian subsidiary was not the foreign reinsurer's PE for the relevant payments, and there was no material showing that technical, consultancy or similar services were rendered. The demand under section 201(1) and interest under section 201(1A) were therefore deleted, and the Revenue's appeal was dismissed.
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