Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
The Appellate Tribunal addressed the issue of TDS u/s 195 on sub contract charges paid to a Singapore company. The Non-Resident company argued it falls under Section 44BB, exempting it from TDS. The Tribunal found the company covered by Section 44BB and the Singapore company has no Permanent Establishment in India, making the payments non-taxable. Consequently, the disallowance u/s 40(a)(ia) was not applicable. The addition by the Assessing Officer was deleted, and the assessee's appeal was allowed.
The Appellate Tribunal addressed the issue of TDS u/s 195 on sub contract charges paid to a Singapore company. The Non-Resident company argued it falls under Section 44BB, exempting it from TDS. The Tribunal found the company covered by Section 44BB and the Singapore company has no Permanent Establishment in India, making the payments non-taxable. Consequently, the disallowance u/s 40(a)(ia) was not applicable. The addition by the Assessing Officer was deleted, and the assessee's appeal was allowed.
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