Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Priority of set-off: brought forward business losses must be adjusted before unabsorbed depreciation; procedural safeguards required for invoking rest...
Whether commission paid to non-resident agents for procuring foreign orders is taxable in India and attracts TDS u/s 195: Tribunal found the services were rendered entirely outside India and the agents had no permanent establishment in India; applying the principle that income not chargeable to tax in India need not attract withholding (as in Transmission Corporation precedent), held the payments are not taxable in India and there is no obligation to deduct tax at source - appeal allowed in favor of the assessee - ITAT
Whether commission paid to non-resident agents for procuring foreign orders is taxable in India and attracts TDS u/s 195: Tribunal found the services were rendered entirely outside India and the agents had no permanent establishment in India; applying the principle that income not chargeable to tax in India need not attract withholding (as in Transmission Corporation precedent), held the payments are not taxable in India and there is no obligation to deduct tax at source - appeal allowed in favor of the assessee - ITAT
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