Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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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