Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
