Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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For fees for technical services, the Tribunal held that the domestic rate under section 115A(1)(b) applied because the remittance was within the RBI automatic route and no separate approval was required on the facts. It construed the approval condition practically, not as a barrier that would make compliance impossible, and applied section 90(2) to permit the assessee to use the more beneficial 10% domestic rate instead of the treaty rate. The education cess ground was dismissed as already settled against the assessee, and interest was treated as consequential.
For fees for technical services, the Tribunal held that the domestic rate under section 115A(1)(b) applied because the remittance was within the RBI automatic route and no separate approval was required on the facts. It construed the approval condition practically, not as a barrier that would make compliance impossible, and applied section 90(2) to permit the assessee to use the more beneficial 10% domestic rate instead of the treaty rate. The education cess ground was dismissed as already settled against the assessee, and interest was treated as consequential.
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