Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions of India-Netherland DTAA - The services in question did not meet the criteria of 'make available' under the India-Netherlands tax treaty. Hence, the payments for these services were not subject to TDS under section 195 and not disallowable under section 40(a)(i). - AT
TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions of India-Netherland DTAA - The services in question did not meet the criteria of 'make available' under the India-Netherlands tax treaty. Hence, the payments for these services were not subject to TDS under section 195 and not disallowable under section 40(a)(i). - AT
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