Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside India. Everest Global Inc. did not have permanent establishment in India. Services provided outside India to assessee under Teaming Agreement and work order. Source of income located outside India and payment made outside India. Fee for technical services paid for earning income from source outside India. Section 9(1)(vii)(b) applied, income not deemed to accrue or arise in India, fees for technical services not taxable. Assessee resident in India, paid fee for technical services to non-resident. Exception applies where fees paid for services utilized in business outside India or for earning income from source outside India. Work order issued outside country for earning income from source outside country. Amount paid covered under exception in section 9(1)(vii)(b). Assessee not required to deduct TDS.
TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside India. Everest Global Inc. did not have permanent establishment in India. Services provided outside India to assessee under Teaming Agreement and work order. Source of income located outside India and payment made outside India. Fee for technical services paid for earning income from source outside India. Section 9(1)(vii)(b) applied, income not deemed to accrue or arise in India, fees for technical services not taxable. Assessee resident in India, paid fee for technical services to non-resident. Exception applies where fees paid for services utilized in business outside India or for earning income from source outside India. Work order issued outside country for earning income from source outside country. Amount paid covered under exception in section 9(1)(vii)(b). Assessee not required to deduct TDS.
Note: It is a system-generated summary and is for quick reference only.
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