Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
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Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
Income-tax exemption for specified regulatory fees and government grants applies subject to non-commercial activity and continuing compliance conditio...
Digital accessibility audit and remediation deadlines extended, while all other disability-compliance obligations for regulated entities remain unchan...
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TDS u/s 195 - assessee in default - payroll services rendered by IBM Philippines to the assessee - as per Article 7(1) of Indian Philippines DTAA, the business profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. Admittedly, there is no permanent establishment of IBM Philippines in India. - the payments received by IBM Philippines shall not be liable for TDS under Section 195 of the IT Act. Therefore, assessee cannot be deemed as an 'assessee in default'. - HC
TDS u/s 195 - assessee in default - payroll services rendered by IBM Philippines to the assessee - as per Article 7(1) of Indian Philippines DTAA, the business profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. Admittedly, there is no permanent establishment of IBM Philippines in India. - the payments received by IBM Philippines shall not be liable for TDS under Section 195 of the IT Act. Therefore, assessee cannot be deemed as an 'assessee in default'. - HC
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