Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Page of 4794
Press 'Enter' after typing page number.
241 to 260 of 95872 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The High Court held that the order passed u/s 201(1) and 201(1A) of the Income Tax Act for treating consultancy charges paid to a foreign company as fees for technical services u/s 9(1)(vii) was invalid as it was passed beyond the period of limitation of four years. The transaction or payment to the foreign company related to the financial years 2006-07, 2007-08, and 2008-09. However, the initiation of proceedings and the order were issued in 2014, which was clearly beyond the four-year limitation period. The High Court, following its earlier decisions, ruled in favor of the assessee and against the revenue authorities on this substantial question of law regarding the validity of the order passed beyond the limitation period for tax deducted at source (TDS) on consultancy charges paid to a foreign entity.
The High Court held that the order passed u/s 201(1) and 201(1A) of the Income Tax Act for treating consultancy charges paid to a foreign company as fees for technical services u/s 9(1)(vii) was invalid as it was passed beyond the period of limitation of four years. The transaction or payment to the foreign company related to the financial years 2006-07, 2007-08, and 2008-09. However, the initiation of proceedings and the order were issued in 2014, which was clearly beyond the four-year limitation period. The High Court, following its earlier decisions, ruled in favor of the assessee and against the revenue authorities on this substantial question of law regarding the validity of the order passed beyond the limitation period for tax deducted at source (TDS) on consultancy charges paid to a foreign entity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
