Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
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 4798
Join Channel
TaxTMI 
