Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
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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