Fake-invoice penalties remain available where taxpayer admissions and records establish unsupported input tax credit claims and false GST documentatio...
Works contract classification applies to permanently installed fire-protection systems, while earthwork and obsolete IGST concessions remain unavailab...
Professional fee recovery for GST refund representation succeeds where direct engagement, fee acknowledgement, and authority are established despite c...
Transfer pricing of intra-group support services requires prescribed benchmarking; unsupported nil valuation and alternate business-expense disallowan...
Foreign sales commission paid to non-resident agents for services performed entirely outside India is not chargeable to tax in India where the agents undertake no activity in India, maintain no business connection or establishment there, and receive the commission abroad. As tax deduction at source applies only to income chargeable in India, remittances in those circumstances do not attract withholding. Chartered Accountant certificates and supporting records may establish the absence of an Indian income nexus or establishment.
Foreign sales commission paid to non-resident agents for services performed entirely outside India is not chargeable to tax in India where the agents undertake no activity in India, maintain no business connection or establishment there, and receive the commission abroad. As tax deduction at source applies only to income chargeable in India, remittances in those circumstances do not attract withholding. Chartered Accountant certificates and supporting records may establish the absence of an Indian income nexus or establishment.
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