Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
The dominant issue was whether payments for rework, segregation and repackaging attracted TDS under s.195 as "fees for technical services" under Expl. 2 to s.9(1)(vii). The tribunal held that the activities were routine and standardized, performed manually or mechanically on predetermined specifications, and did not involve specialized expertise or any new scientific process; the Revenue also did not dispute the nature of work. Consequently, the deletion of the disallowance was affirmed and the Revenue's appeal was dismissed. - ITAT
The dominant issue was whether payments for rework, segregation and repackaging attracted TDS under s.195 as "fees for technical services" under Expl. 2 to s.9(1)(vii). The tribunal held that the activities were routine and standardized, performed manually or mechanically on predetermined specifications, and did not involve specialized expertise or any new scientific process; the Revenue also did not dispute the nature of work. Consequently, the deletion of the disallowance was affirmed and the Revenue's appeal was dismissed. - ITAT
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