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...
Diamond grading and certification charges for examining diamonds and issuing reports of their physical characteristics do not constitute fees for technical services merely because the provider uses specialised knowledge, equipment or qualified personnel. Where the service neither imparts managerial, technical or consultancy advice nor enables the recipient to perform diamond grading independently, the treaty "make available" condition is not met. Payments not chargeable to tax in India do not trigger withholding obligations on payments to non-residents. Accordingly, the demand for failure to deduct tax and consequential interest was deleted, and the Revenue's appeals were dismissed.
Diamond grading and certification charges for examining diamonds and issuing reports of their physical characteristics do not constitute fees for technical services merely because the provider uses specialised knowledge, equipment or qualified personnel. Where the service neither imparts managerial, technical or consultancy advice nor enables the recipient to perform diamond grading independently, the treaty "make available" condition is not met. Payments not chargeable to tax in India do not trigger withholding obligations on payments to non-residents. Accordingly, the demand for failure to deduct tax and consequential interest was deleted, and the Revenue's appeals were dismissed.
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