Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently br...
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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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