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 - sales commission expenses paid to agents outside India - The commission income earned by foreign agents for services rendered outside India does not accrue or arise in India and, therefore, is not subject to tax in India. Consequently, there is no requirement for the payer to deduct tax at source on such commission payments under section 40(a)(i) of the Income Tax Act, 1961. This principle is based on the proposition of law laid down by the Supreme Court of India - AT
TDS u/s 195 - sales commission expenses paid to agents outside India - The commission income earned by foreign agents for services rendered outside India does not accrue or arise in India and, therefore, is not subject to tax in India. Consequently, there is no requirement for the payer to deduct tax at source on such commission payments under section 40(a)(i) of the Income Tax Act, 1961. This principle is based on the proposition of law laid down by the Supreme Court of India - AT
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