Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The HC quashed the Assessing Officer's rejection of the petitioner's application for nil withholding tax certificate under s195(3) and s197 of the Income Tax Act. The Court noted that the petitioner, a German tax resident operating aircraft in international traffic, had received nil withholding certificates for over a decade with no change in the nature of services rendered. The income was not chargeable to tax in India under Article 8 of the India-Germany DTAA. The AO failed to provide adequate reasoning for imposing a 0.10% withholding rate instead of the nil rate claimed. Given the petitioner's consistent tax treatment in previous years and the imminent expiry of FY 2024-25, the Court declined to remand the matter and invalidated the impugned certificate.
The HC quashed the Assessing Officer's rejection of the petitioner's application for nil withholding tax certificate under s195(3) and s197 of the Income Tax Act. The Court noted that the petitioner, a German tax resident operating aircraft in international traffic, had received nil withholding certificates for over a decade with no change in the nature of services rendered. The income was not chargeable to tax in India under Article 8 of the India-Germany DTAA. The AO failed to provide adequate reasoning for imposing a 0.10% withholding rate instead of the nil rate claimed. Given the petitioner's consistent tax treatment in previous years and the imminent expiry of FY 2024-25, the Court declined to remand the matter and invalidated the impugned certificate.
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