Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
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The ITAT held that the reassessment initiated u/s 147 was without valid jurisdiction and therefore void. The assessee, a UAE tax resident foreign company, had only interest income from an Indian payer, on which tax had been duly withheld at 12.5% in accordance with Article 11 of the India-UAE DTAA and s.195. As the conditions of s.115A(5) were satisfied, the assessee was not obliged to file a return for AY 2012-13, rendering the AO's sole basis for reopening-non-filing of return-untenable. Further, the AO wrongly taxed double the actual interest income without supporting material. The reassessment order was quashed and the assessee's appeal allowed.
The ITAT held that the reassessment initiated u/s 147 was without valid jurisdiction and therefore void. The assessee, a UAE tax resident foreign company, had only interest income from an Indian payer, on which tax had been duly withheld at 12.5% in accordance with Article 11 of the India-UAE DTAA and s.195. As the conditions of s.115A(5) were satisfied, the assessee was not obliged to file a return for AY 2012-13, rendering the AO's sole basis for reopening-non-filing of return-untenable. Further, the AO wrongly taxed double the actual interest income without supporting material. The reassessment order was quashed and the assessee's appeal allowed.
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