Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
The case dealt with the taxability of income in India related to royalty receipts and Tax Deducted at Source (TDS) u/s 195. The respondent did not deduct tax on remittance to a foreign party for software procurement, claiming it wasn't royalty. Both the CIT(A) and Tribunal agreed. The High Court referred to precedent stating non-retrospective application of Explanation 6 to Section 9(1)(vi) of the Income Tax Act. The Supreme Court upheld this view, clarifying that Explanation 6 cannot be applied retrospectively. Rejecting the Revenue's attempt to apply Explanation 4 retrospectively, the court ruled in favor of the assessee.
The case dealt with the taxability of income in India related to royalty receipts and Tax Deducted at Source (TDS) u/s 195. The respondent did not deduct tax on remittance to a foreign party for software procurement, claiming it wasn't royalty. Both the CIT(A) and Tribunal agreed. The High Court referred to precedent stating non-retrospective application of Explanation 6 to Section 9(1)(vi) of the Income Tax Act. The Supreme Court upheld this view, clarifying that Explanation 6 cannot be applied retrospectively. Rejecting the Revenue's attempt to apply Explanation 4 retrospectively, the court ruled in favor of the assessee.
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