Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
The ITAT Chennai addressed several issues. Firstly, regarding TDS u/s 195/192, it held that payments made to overseas group entities for relocation expenses of secondment employees were not subject to TDS as they were reimbursement of internal business costs, not taxable income. The matter was remitted to the AO for verification. Secondly, non-credit of DDT paid u/s 115O was remitted for verification of the amount paid. Thirdly, DDT liability u/s 115-O for dividends paid to a UK entity was to be decided by lower authorities. Lastly, lease rental payments were allowed as deductible expenses, with depreciation on assets taken on finance lease being part of the disallowance under section 32. The confusion created by the AO was clarified, and the Revenue's appeal on this issue was dismissed.
The ITAT Chennai addressed several issues. Firstly, regarding TDS u/s 195/192, it held that payments made to overseas group entities for relocation expenses of secondment employees were not subject to TDS as they were reimbursement of internal business costs, not taxable income. The matter was remitted to the AO for verification. Secondly, non-credit of DDT paid u/s 115O was remitted for verification of the amount paid. Thirdly, DDT liability u/s 115-O for dividends paid to a UK entity was to be decided by lower authorities. Lastly, lease rental payments were allowed as deductible expenses, with depreciation on assets taken on finance lease being part of the disallowance under section 32. The confusion created by the AO was clarified, and the Revenue's appeal on this issue was dismissed.
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