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    September 29, 2026   Case Laws Income Tax
    Clean-slate corporate sales prevent reassessment for extinguished liabilities, while section 148A orders cannot add unnotified allegations.
    September 29, 2026   Case Laws Income Tax
    Good faith and due diligence under Explanation 7 protect transfer pricing positions involving debatable TNMM application differences.
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
    Specificity in search-penalty notices is essential: failure to state the applicable charge and rate invalidates the proceedings.
    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Income Tax
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    September 29, 2026   Case Laws Customs
    Interest on redemption-related customs duty runs only from adjudicated liability, permitting limited writ review despite an alternative remedy.
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September 29, 2026   Case Laws Income Tax
Clean-slate corporate sales prevent reassessment for extinguished liabilities, while section 148A orders cannot add unnotified allegations.
September 29, 2026   Case Laws Income Tax
Good faith and due diligence under Explanation 7 protect transfer pricing positions involving debatable TNMM application differences.
September 29, 2026   Case Laws Income Tax
Audit-report timing: Form 10B filed within an extended return deadline preserves charitable-trust exemption despite rejected condonation.
September 29, 2026   Case Laws Income Tax
Beneficial ownership of State funds excludes interest taxation, while project-transfer signature bonuses remain business revenue receipts.
September 29, 2026   Case Laws Income Tax
Parallel reassessment on identical search-assessment additions was quashed because it would directly affect pending tax appeals.
September 29, 2026   Case Laws Income Tax
SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are examined.
September 29, 2026   Case Laws Income Tax
Specificity in search-penalty notices is essential: failure to state the applicable charge and rate invalidates the proceedings.
September 29, 2026   Case Laws Income Tax
Inadequate TDS inquiry into commission expenditure can justify revision where material discrepancies remain unexplained after generic verification.
September 29, 2026   Case Laws Income Tax
Ad Hoc Disallowance of Livestock Purchases Fails Without Identified Defects or Evidence of Non-Genuine Transactions.
September 29, 2026   Case Laws Income Tax
Section 69A Addition: Income included in taxable income but omitted from return schedule, alongside appeal-limitation exclusion.
September 29, 2026   Case Laws Income Tax
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreements.
September 29, 2026   Case Laws Income Tax
Reassessment limitation excludes the section 148A(b) response period, while political donation deductions require proof beyond banking records.
September 29, 2026   Case Laws Income Tax
Source-of-source burden shifts to Revenue after cash-gift donors' identity, genuineness, and basic creditworthiness are established.
September 29, 2026   Case Laws Income Tax
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investments.
September 29, 2026   Case Laws Income Tax
Evidentiary substantiation in assessments: unsupported cash deposits, land-facilitation receipts, and GST sales supported additions and business-income treatment.
September 29, 2026   Case Laws Income Tax
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for transfer-pricing purposes.
September 29, 2026   Case Laws Income Tax
Redevelopment hardship compensation is capital, while gross salary reporting alone cannot determine taxability or defeat evidenced deductions.
September 29, 2026   Case Laws Income Tax
Treaty-rate dividend tax refund claim remitted pending larger Bench ruling; commercially expedient media research expenditure remained deductible.
September 29, 2026   Case Laws Income Tax
Online gaming winnings: Skill-based prizes remain taxable, but only real net gains may be assessed
September 29, 2026   Case Laws Customs
Interest on redemption-related customs duty runs only from adjudicated liability, permitting limited writ review despite an alternative remedy.

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Home › Highlights › Income Tax › 2015 › August, 2015 › This
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Income Tax

Liability for deduction of TDS u/s 195 r/w S.197 - the income...

US Entity's Income in India Not Liable for TDS Due to No Permanent Establishment u/ss 195 & 197.

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Income Tax August 26, 2015 Case Laws HC
Liability for deduction of TDS u/s 195 r/w S.197 - the income earned by M/s Sheraton International, USA in India was not liable for deduction of TDS u/s 195 r/w S.197 of the Act, in respect of payments made by the assessee as they did not have a permanent establishing in India as per S.9 r/w its explanation - HC
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