Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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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