Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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