Provisional attachment under Prevention of Money Laundering Act requires exhaustion of statutory remedies; impugned order set aside, appeal to tribuna...
Restoration of property under Prevention of Money Laundering Act after attachment dispute rendered academic; possession directed to successful resolut...
Goods Transport Agency services via e commerce portals: consignment note creates custody and liability and enables exemption for unregistered recipien...
Reverse charge and assignment of royalty collection: exemption for excess royalty collectors subject to reconciliation; leaseholders remain liable und...
Whether payments to distributors for pre-paid products attracted TDS under Section 194H - applying the Supreme Court's restricted construction of "agent" (limited to persons able to affect the principal's legal position by contract or disposition of property and assessed by the indicia in para 8), the relationship was not that of an agent within Explanation (i) to Section 194H; reasoning distinguishing principal-agent from master-servant and emphasizing contract/disposition indicia. Consequence: no legal obligation to deduct TDS on the discount/income element received by distributors; Section 194H held inapplicable - decision for the assessee. - ITAT
Whether payments to distributors for pre-paid products attracted TDS under Section 194H - applying the Supreme Court's restricted construction of "agent" (limited to persons able to affect the principal's legal position by contract or disposition of property and assessed by the indicia in para 8), the relationship was not that of an agent within Explanation (i) to Section 194H; reasoning distinguishing principal-agent from master-servant and emphasizing contract/disposition indicia. Consequence: no legal obligation to deduct TDS on the discount/income element received by distributors; Section 194H held inapplicable - decision for the assessee. - ITAT
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