Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
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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