Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
The High Court addressed the validity of a certification issued u/s 197 for FY 2023-24, where a "Nil" withholding tax certificate was sought but a 15% withholding tax rate was prescribed. Since FY 2023-24 has ended, the petition was disposed with liberty to apply u/s 197 for FY 2024-25. Any new application will be reviewed independently. The petitioner may claim benefits as per CBDT Circular if successful. The petitioner retains the right to challenge the impugned order to safeguard its interests. All rights and contentions of parties are preserved.
The High Court addressed the validity of a certification issued u/s 197 for FY 2023-24, where a "Nil" withholding tax certificate was sought but a 15% withholding tax rate was prescribed. Since FY 2023-24 has ended, the petition was disposed with liberty to apply u/s 197 for FY 2024-25. Any new application will be reviewed independently. The petitioner may claim benefits as per CBDT Circular if successful. The petitioner retains the right to challenge the impugned order to safeguard its interests. All rights and contentions of parties are preserved.
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