Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Non-payment of tax for Assessment Years 2005-06 and 2006-07 - Liability to pay interest u/s 234B. Prior to the insertion of proviso to Section 209(1), if the payer defaulted in deducting tax at source from payments to non-residents, the non-resident was not absolved from paying taxes, and the question of advance tax payment did not arise. The Supreme Court disposed of the appeal due to low tax effect, keeping any question of law open. Pending applications were also disposed of.
Non-payment of tax for Assessment Years 2005-06 and 2006-07 - Liability to pay interest u/s 234B. Prior to the insertion of proviso to Section 209(1), if the payer defaulted in deducting tax at source from payments to non-residents, the non-resident was not absolved from paying taxes, and the question of advance tax payment did not arise. The Supreme Court disposed of the appeal due to low tax effect, keeping any question of law open. Pending applications were also disposed of.
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