Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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...
The ITAT examined two issues: (1) Tax deduction at source (TDS) u/s 195 on payments to seconded employees, and (2) disallowance of technology fees paid to the parent company. Regarding TDS, the ITAT found clauses indicating the seconded employees had a lien on their jobs with the parent company, and the assessee provided tools/equipment and indemnified the parent company. These aspects required fresh examination by the Assessing Officer (AO) to determine the true nature of payments. On technology fees disallowance, the ITAT held that the AO/TPO cannot disallow genuine expenses merely because no benefits accrued. However, the assessee failed to substantiate services rendered by the parent company through cogent evidence. The ITAT remitted this issue to the AO/TPO for fresh adjudication after considering all evidence filed. The assessee's appeal was allowed for statistical purposes.
The ITAT examined two issues: (1) Tax deduction at source (TDS) u/s 195 on payments to seconded employees, and (2) disallowance of technology fees paid to the parent company. Regarding TDS, the ITAT found clauses indicating the seconded employees had a lien on their jobs with the parent company, and the assessee provided tools/equipment and indemnified the parent company. These aspects required fresh examination by the Assessing Officer (AO) to determine the true nature of payments. On technology fees disallowance, the ITAT held that the AO/TPO cannot disallow genuine expenses merely because no benefits accrued. However, the assessee failed to substantiate services rendered by the parent company through cogent evidence. The ITAT remitted this issue to the AO/TPO for fresh adjudication after considering all evidence filed. The assessee's appeal was allowed for statistical purposes.
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