Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Binding interim High Court directions treating Leave Travel Concession reimbursements as non-income for TDS purposes prevented bank branches from being treated as assessees in default for non-deduction on reimbursements involving foreign travel. Section 201 liability arises only where tax was not deducted despite a subsisting legal obligation. Compliance with operative interim directions eclipsed that obligation for the relevant period, even though employees remained liable if the writ petition failed. A subsequent merits decision on the exemption issue could not retrospectively impose default liability. Consequently, demands for default and related interest were set aside.
Binding interim High Court directions treating Leave Travel Concession reimbursements as non-income for TDS purposes prevented bank branches from being treated as assessees in default for non-deduction on reimbursements involving foreign travel. Section 201 liability arises only where tax was not deducted despite a subsisting legal obligation. Compliance with operative interim directions eclipsed that obligation for the relevant period, even though employees remained liable if the writ petition failed. A subsequent merits decision on the exemption issue could not retrospectively impose default liability. Consequently, demands for default and related interest were set aside.
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TaxTMI 
TaxTMI 
of 4888 
