Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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