Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
The case involved reimbursement of expenses u/s 195 of the Income Tax Act, concerning payments made for services rendered outside India. The payments to various entities were found to fall under exclusionary provisions of Section 9(1)(vii)(b), as they were for earning income from a source outside India. Disallowance u/s 40(a)(i) was deemed unwarranted and ordered to be deleted. Transactions with Carnegie Mellon University, Call Centre School LLC, APM Group, British Computer Society, RADTAC, and an individual for professional services were similarly analyzed and disallowances were overturned, citing legal provisions and tax residency status. The ITAT allowed the appeals of the assessee in all instances.
The case involved reimbursement of expenses u/s 195 of the Income Tax Act, concerning payments made for services rendered outside India. The payments to various entities were found to fall under exclusionary provisions of Section 9(1)(vii)(b), as they were for earning income from a source outside India. Disallowance u/s 40(a)(i) was deemed unwarranted and ordered to be deleted. Transactions with Carnegie Mellon University, Call Centre School LLC, APM Group, British Computer Society, RADTAC, and an individual for professional services were similarly analyzed and disallowances were overturned, citing legal provisions and tax residency status. The ITAT allowed the appeals of the assessee in all instances.
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