Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Additions for non-deduction of TDS - Sec 40(a)(ia) is a disabling provision which and not an enabling provision. - there is nothing in the language of Sec.40(a)(ia) to the effect that it is only when an Assessee is treated as an Assessee in default under Chapter XVII B of the Act by an order passed u/s.201(1) of the Act, can a disallowance be made u/s.40(a)(ia).
Additions for non-deduction of TDS - Sec 40(a)(ia) is a disabling provision which and not an enabling provision. - there is nothing in the language of Sec.40(a)(ia) to the effect that it is only when an Assessee is treated as an Assessee in default under Chapter XVII B of the Act by an order passed u/s.201(1) of the Act, can a disallowance be made u/s.40(a)(ia).
Note: It is a system-generated summary and is for quick reference only.