Customs valuation and import permissibility conflict resolved: accepted enhancement of transaction value removes liability for confiscation and penalt...
Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
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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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