Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
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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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