Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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ITAT held that payments for transponder charges to Intelsat Global Sales and Marketing Limited do not constitute royalty under Section 9(1)(vi) of the Income Tax Act or the relevant Double Taxation Avoidance Agreement. Following precedents from Delhi HC and coordinate benches, the tribunal determined that the assessee is not liable to deduct tax at source under Section 195. No contrary evidence or judicial orders were presented to challenge prior rulings. The revenue department's appeal was consequently dismissed, affirming the earlier CIT(A) decision and maintaining the existing jurisprudential interpretation regarding such technical service payments.
ITAT held that payments for transponder charges to Intelsat Global Sales and Marketing Limited do not constitute royalty under Section 9(1)(vi) of the Income Tax Act or the relevant Double Taxation Avoidance Agreement. Following precedents from Delhi HC and coordinate benches, the tribunal determined that the assessee is not liable to deduct tax at source under Section 195. No contrary evidence or judicial orders were presented to challenge prior rulings. The revenue department's appeal was consequently dismissed, affirming the earlier CIT(A) decision and maintaining the existing jurisprudential interpretation regarding such technical service payments.
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