Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
TDS u/s 195 - Addition u/s 40(a)(ia) - Commission paid outside India not chargeable under Income Tax Act. HC held that if business operations carried out outside India, income derived therefrom not deemed to accrue or arise in India. Commission paid for services rendered by non-resident outside India not subject to TDS u/s 195. Rectification proceedings to deny deduction for such commission payment without jurisdiction as no mistake apparent. Impugned notice, rejection of preliminary objections and consequential reassessment proceedings quashed. Assessee's appeal allowed.
TDS u/s 195 - Addition u/s 40(a)(ia) - Commission paid outside India not chargeable under Income Tax Act. HC held that if business operations carried out outside India, income derived therefrom not deemed to accrue or arise in India. Commission paid for services rendered by non-resident outside India not subject to TDS u/s 195. Rectification proceedings to deny deduction for such commission payment without jurisdiction as no mistake apparent. Impugned notice, rejection of preliminary objections and consequential reassessment proceedings quashed. Assessee's appeal allowed.
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