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Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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The Appellate Tribunal addressed the issue of Tax Deducted at Source (TDS) under section 195, specifically disallowance under section 40(a)(i) for payments labeled as 'Royalty' under section 9(1)(vi). The AO disallowed payments to VBSNI equating them to previous payments to MCI Communication Service, treated as 'Royalty'. However, the Tribunal ruled that VBSNI payments did not qualify as 'Royalty' under DTAA, thus no TDS was required. The Tribunal's decision, upheld by the High Court, directed deletion of the disallowance. The appeal by the revenue was dismissed.
The Appellate Tribunal addressed the issue of Tax Deducted at Source (TDS) under section 195, specifically disallowance under section 40(a)(i) for payments labeled as 'Royalty' under section 9(1)(vi). The AO disallowed payments to VBSNI equating them to previous payments to MCI Communication Service, treated as 'Royalty'. However, the Tribunal ruled that VBSNI payments did not qualify as 'Royalty' under DTAA, thus no TDS was required. The Tribunal's decision, upheld by the High Court, directed deletion of the disallowance. The appeal by the revenue was dismissed.
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