Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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