Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
TDS treatment of commission paid to travel agents is addressed: where agents have already paid income tax on supplementary commission, no further recovery of TDS shortfall is warranted, though interest under the income tax penal provision is to be computed and demanded. The assessing officer is directed to compute and issue a demand notice for interest payable from date of default until agents payment, and may verify whether agents actually paid tax. If any agents remain unpaid, Revenue may recover the TDS shortfall from the payer, but imposition of penalties on the payer is restricted by the protective penalty provision.
TDS treatment of commission paid to travel agents is addressed: where agents have already paid income tax on supplementary commission, no further recovery of TDS shortfall is warranted, though interest under the income tax penal provision is to be computed and demanded. The assessing officer is directed to compute and issue a demand notice for interest payable from date of default until agents payment, and may verify whether agents actually paid tax. If any agents remain unpaid, Revenue may recover the TDS shortfall from the payer, but imposition of penalties on the payer is restricted by the protective penalty provision.
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