Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Application for NIL rate TDS deduction certificate u/s 197 - The High court noted that the project was in Bangladesh, and no part of it was situated in India. The payments to ICT for the project were made in Bangladesh, and the services rendered by the petitioner to ICT were governed by the DTAA (Double Taxation Avoidance Agreement) between the USA and India. Under Article 12 of the DTAA, only fees for 'included services' are taxable in the source state, not the fees for technical services in question. - Since no material showed the involvement of the petitioner's Indian PE in the project, the court inferred no taxable event had occurred in India. - Respondents directed to consider granting a nil rate TDS deduction certificate.
Application for NIL rate TDS deduction certificate u/s 197 - The High court noted that the project was in Bangladesh, and no part of it was situated in India. The payments to ICT for the project were made in Bangladesh, and the services rendered by the petitioner to ICT were governed by the DTAA (Double Taxation Avoidance Agreement) between the USA and India. Under Article 12 of the DTAA, only fees for 'included services' are taxable in the source state, not the fees for technical services in question. - Since no material showed the involvement of the petitioner's Indian PE in the project, the court inferred no taxable event had occurred in India. - Respondents directed to consider granting a nil rate TDS deduction certificate.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
