Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Tax deduction at source on payments to non-residents arises only if the payment contains income chargeable to tax in India. A tax residency certificate affects access to treaty relief, but its absence does not itself establish a domestic tax charge. Commission for services performed outside India, without evidence of services or business operations in India, is not shown to be taxable in India; consequently, no tax deduction or related disallowance applies, subject to arithmetical verification. Form 15CB descriptions do not conclusively establish a payment's character, which must be determined from agreements, invoices and services rendered. A disallowance may remain where the taxpayer accepts the proposed variation and does not rebut it.
Tax deduction at source on payments to non-residents arises only if the payment contains income chargeable to tax in India. A tax residency certificate affects access to treaty relief, but its absence does not itself establish a domestic tax charge. Commission for services performed outside India, without evidence of services or business operations in India, is not shown to be taxable in India; consequently, no tax deduction or related disallowance applies, subject to arithmetical verification. Form 15CB descriptions do not conclusively establish a payment's character, which must be determined from agreements, invoices and services rendered. A disallowance may remain where the taxpayer accepts the proposed variation and does not rebut it.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
