Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
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.
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