Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
TDS u/s 194C or 194I - car rent expenses incurred by assessee - variation in threshold limit - the assessee has deducted TDS u/s. 194I in respect of one of the lessor, from whom vehicle was taken on lease and that, the payment exceeded the threshold limit of ₹ 1,80,000/-. There is no malafide intention of assessee to evade tax. In respect of the remaining payments, the threshold limit did not exceed and therefore TDS need not have been deducted. We therefore direct the Ld.AO to delete the disallowance made in respect of the same. - AT
TDS u/s 194C or 194I - car rent expenses incurred by assessee - variation in threshold limit - the assessee has deducted TDS u/s. 194I in respect of one of the lessor, from whom vehicle was taken on lease and that, the payment exceeded the threshold limit of ₹ 1,80,000/-. There is no malafide intention of assessee to evade tax. In respect of the remaining payments, the threshold limit did not exceed and therefore TDS need not have been deducted. We therefore direct the Ld.AO to delete the disallowance made in respect of the same. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
