Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Application u/s 197 - reduction of withholding tax - petitioner had sought a certificate, at “NIL” rate of tax - request to issue certificate at lower was rejected - Reduction of withholding tax u/s 195 is the rule, it is required to be borne in mind, that deduction of withholding tax morphs into an obligation, only if the sum received is chargeable to tax. The petitioner’s entire case is, that the sum that it receives under the Distributor Agreement is not chargeable to tax. - Authorities directed to re-examine the issue - HC
Application u/s 197 - reduction of withholding tax - petitioner had sought a certificate, at “NIL” rate of tax - request to issue certificate at lower was rejected - Reduction of withholding tax u/s 195 is the rule, it is required to be borne in mind, that deduction of withholding tax morphs into an obligation, only if the sum received is chargeable to tax. The petitioner’s entire case is, that the sum that it receives under the Distributor Agreement is not chargeable to tax. - Authorities directed to re-examine the issue - HC
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