Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
TDS u/s 195 - assessee has already deducted tax under section 192 of the Act in respect of salary cost of expatriate employees - where profit attribution to a PE is based on a notional calculation rather than actual payments (e.g., markup on salaries of expatriate employees), the assessee cannot be expected to deduct tax on such notional income, especially when tax has already been deducted on the actual payments under different sections of the Income-tax Act. - AT
TDS u/s 195 - assessee has already deducted tax under section 192 of the Act in respect of salary cost of expatriate employees - where profit attribution to a PE is based on a notional calculation rather than actual payments (e.g., markup on salaries of expatriate employees), the assessee cannot be expected to deduct tax on such notional income, especially when tax has already been deducted on the actual payments under different sections of the Income-tax Act. - AT
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