Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Payments to non-residents for travel-agent and hotel-booking commissions did not attract TDS on the facts found, because the assessee had furnished Form 15CB for each transaction, deducted and deposited tax wherever applicable, and filed the TDS returns. The HC accepted the Tribunal's finding that the commission payments to banks, credit card companies, travel agents and related service providers were not sums liable for deduction under section 195 in those circumstances. Since the assessee had complied with the TDS requirements and there was no adverse reporting in Form 3CD on non-deduction, it could not be treated as an assessee in default under section 201, and the deletion of section 201(1) and 201(1A) action was upheld.
Payments to non-residents for travel-agent and hotel-booking commissions did not attract TDS on the facts found, because the assessee had furnished Form 15CB for each transaction, deducted and deposited tax wherever applicable, and filed the TDS returns. The HC accepted the Tribunal's finding that the commission payments to banks, credit card companies, travel agents and related service providers were not sums liable for deduction under section 195 in those circumstances. Since the assessee had complied with the TDS requirements and there was no adverse reporting in Form 3CD on non-deduction, it could not be treated as an assessee in default under section 201, and the deletion of section 201(1) and 201(1A) action was upheld.
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