Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Beneficial DTAA withholding rates apply to royalty and fees for technical services paid to non-residents where those rates are more favourable than domestic law. Section 90(2) gives treaty provisions priority in such circumstances. The higher tax-deduction requirement for non-furnishing of PAN under section 206AA is procedural and does not override the applicable beneficial treaty rate. Accordingly, tax deducted at the relevant DTAA rate does not create a short-deduction liability merely because the PAN-based domestic withholding rate is higher; the related demand and consequential interest were deleted.
Beneficial DTAA withholding rates apply to royalty and fees for technical services paid to non-residents where those rates are more favourable than domestic law. Section 90(2) gives treaty provisions priority in such circumstances. The higher tax-deduction requirement for non-furnishing of PAN under section 206AA is procedural and does not override the applicable beneficial treaty rate. Accordingly, tax deducted at the relevant DTAA rate does not create a short-deduction liability merely because the PAN-based domestic withholding rate is higher; the related demand and consequential interest were deleted.
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