Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
TDS on certain foreign payments - reimbursements of expenses - independent professional service - The case involves a dispute over the classification of services obtained from foreign entities by the appellant, a law firm proprietor. While the appellant argues that these services constitute legal services exempt from TDS, the Assessing Officer contends that they fall under 'Fees for Technical Services', warranting TDS deductions. The court directs a reevaluation of the nature of services and compliance with DTAA provisions, highlighting the appellant's right to seek exemption under 'Independent professional services'.
TDS on certain foreign payments - reimbursements of expenses - independent professional service - The case involves a dispute over the classification of services obtained from foreign entities by the appellant, a law firm proprietor. While the appellant argues that these services constitute legal services exempt from TDS, the Assessing Officer contends that they fall under 'Fees for Technical Services', warranting TDS deductions. The court directs a reevaluation of the nature of services and compliance with DTAA provisions, highlighting the appellant's right to seek exemption under 'Independent professional services'.
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