Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
☰   Show Results ❯
    Jurisdictional satisfaction for concealment penalty cannot be created later by substituting a distinct penal provision after assessment.
    Delayed trade receivables require independent arm's length benchmarking after the agreed credit period, using currency-appropriate interest rates.
    Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
    Arm's length pricing of captive electricity follows the distribution licensee's supply rate, while penalty initiation challenges remain premature.
    Pass-through associated enterprise purchases require no arm's length adjustment where credit notes align prices with the unrelated supplier.
    Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
    Tax withholding on settlement compensation requires an identified statutory obligation before a disallowance can arise.
    Compulsorily convertible debentures remain debt until conversion, preventing transfer-pricing recharacterisation as equity without the GAAR procedure.
    Reciprocal plot exchanges: Consideration in kind prevents section 43CA valuation addition where no stamp-duty shortfall exists.
    Project-import contract registration before importation determines Heading 98.01 eligibility, while Section 18A permits qualifying post-clearance Bill...
    Clean slate protection prevents enforcement of pre-CIRP export obligations through Denied Entry List restrictions after resolution approval.
    Resolution-plan feasibility fails where SEZ land conversion lacks consent and the Information Memorandum conceals regulatory uncertainty.
    GST limitation turns on issuance of substantive notices and orders, not later electronic DRC summaries, preserving appellate review.
    Rule 138B authorisation and alternative appellate remedies limited the writ challenge to confiscation proceedings involving scrap-goods transport.
    Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
    Writ jurisdiction over CGST penalties requires a clear natural-justice breach; record-dependent challenges belong in statutory appeal.
    Anticipatory bail under GST requires a communicated arrest-authorisation order; summons alone make a pre-arrest petition premature.
    Proof of statutory breach limits strict-liability transit penalties where consignee-address errors are bona fide and goods match documents.
    Part B e-way bill exception protects initial intrastate movement to transporter premises from tax penalties.
    Electronic Cash Ledger balances do not discharge GST return liabilities until debit, sustaining interest on delayed return filing.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Back

All Highlights

TDS u/s 195 - Since there is no transfer of technology or use of...

Payments for Affiliation Not Classified as 'Royalty' u/s 195: No Tech Transfer Involved, Says IT Act & DTAA.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Income Tax July 6, 2018 Case Laws AT
TDS u/s 195 - Since there is no transfer of technology or use of any technology and payment is only simply for affiliation, the above amount cannot be considered as ‘royalty’ either under the provisions of Income Tax Act or under the provisions of DTAA.

Topics

Acts Income Tax