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...
Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The High Court determined the services availed to be managerial, not technical or consultancy that "make available" technical knowledge, skill, or processes as required by Article 13 of the DTAA. - The High Court found the AAR's interpretation flawed, emphasizing that the services in question did not satisfy the criteria of "making available" technical knowledge as per the DTAA. Consequently, it set aside the AAR's order mandating tax withholding under section 195 of the Income Tax Act, 1961.
Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The High Court determined the services availed to be managerial, not technical or consultancy that "make available" technical knowledge, skill, or processes as required by Article 13 of the DTAA. - The High Court found the AAR's interpretation flawed, emphasizing that the services in question did not satisfy the criteria of "making available" technical knowledge as per the DTAA. Consequently, it set aside the AAR's order mandating tax withholding under section 195 of the Income Tax Act, 1961.
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