Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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.
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