Request-driven road restoration attracts reverse-charge GST, not governmental-function treatment or compensatory-damages status for business recipient...
Road restoration charges for commercial pipeline works are taxable Government services, with reverse charge liability and no public-function exemption...
Model-wise import cap monitoring cannot justify withholding used multifunction machines where all-India tracking is absent and full security is furnis...
TDS u/s 195 - Since the Singapore HO recovered the same amount from the Indian BO as was incurred by it to third parties without any profit element, the receipt cannot be construed as “other sum chargeable under the provisions of this Act” so as to warrant deduction of tax at source u/s.195 of the Act by the Indian BO. Once it is held that TDS was not necessary, there can be no question of disallowance u/s.40(a)(i). - AT
TDS u/s 195 - Since the Singapore HO recovered the same amount from the Indian BO as was incurred by it to third parties without any profit element, the receipt cannot be construed as “other sum chargeable under the provisions of this Act” so as to warrant deduction of tax at source u/s.195 of the Act by the Indian BO. Once it is held that TDS was not necessary, there can be no question of disallowance u/s.40(a)(i). - AT
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