Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
TDS u/s 195 - withholding tax - payments made to the foreign firms and non-residents - rendering the services was attracting and motivating the international students for taking admission in assessee’s university - it cannot be regarded as consultancy services provided to the assessee - these agents have not received the consideration in respect of their services in India or deemed to be received in India on their behalf as they do not have any PE or agent in India. The amount has been remitted directly to them outside India by the assessee. Therefore, provisions of section 5(a) is not applicable. - No TDS liability - AT
TDS u/s 195 - withholding tax - payments made to the foreign firms and non-residents - rendering the services was attracting and motivating the international students for taking admission in assessee’s university - it cannot be regarded as consultancy services provided to the assessee - these agents have not received the consideration in respect of their services in India or deemed to be received in India on their behalf as they do not have any PE or agent in India. The amount has been remitted directly to them outside India by the assessee. Therefore, provisions of section 5(a) is not applicable. - No TDS liability - AT
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