Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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TDS u/s 195 - Since Section 40(a)(i) as it stood in AY 2006-07 continued to discriminate in the above manner and was inconsistent with Article 24(3) of the Indo Japan DTAA or Article 26 (3) of the Indo US DTAA, the Assessee was entitled to rely on the above DTAA provisions to claim deduction of the sums paid to entities in Japan and USA. - HC
TDS u/s 195 - Since Section 40(a)(i) as it stood in AY 2006-07 continued to discriminate in the above manner and was inconsistent with Article 24(3) of the Indo Japan DTAA or Article 26 (3) of the Indo US DTAA, the Assessee was entitled to rely on the above DTAA provisions to claim deduction of the sums paid to entities in Japan and USA. - HC
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