Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as royalty taxable in India. Assessee not liable to deduct TDS as payments were reimbursements for expenses incurred by non-resident attorneys for renewal of patents abroad and to registration authorities. Professional fees paid to foreign attorneys without PE in India, not taxable. Payments not income chargeable to tax in India u/s 195, no TDS obligation. Coordinate bench held such reimbursements and official purpose payments not professional/technical services, not taxable income. Payments to non-residents without PE for overseas services and reimbursements not subject to TDS u/s 195. Disallowance deleted, assessee's appeal allowed.
TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as royalty taxable in India. Assessee not liable to deduct TDS as payments were reimbursements for expenses incurred by non-resident attorneys for renewal of patents abroad and to registration authorities. Professional fees paid to foreign attorneys without PE in India, not taxable. Payments not income chargeable to tax in India u/s 195, no TDS obligation. Coordinate bench held such reimbursements and official purpose payments not professional/technical services, not taxable income. Payments to non-residents without PE for overseas services and reimbursements not subject to TDS u/s 195. Disallowance deleted, assessee's appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
