Pre-trial bail granted where custodial period, documentary prosecution, and magistrate-triable offence favor release subject to surety and no witness ...
Allowability of Salary Exemptions: Form 16 entries can substantiate HRA and other salary exemptions, and home loan interest is deductible for a self-o...
Capital gains exemption: payment for plot, architect fees and bona fide commencement of construction can satisfy utilisation requirement and secure re...
ITAT considered whether cross-border corporate service payments attracted TDS under section 195 by examining classification as fees for technical services and existence of a permanent establishment. The tribunal found the services did not make available technical knowledge, experience, skill, know-how or processes, so the payments did not qualify as FTS under the IndiaSingapore DTAA and were at best business profits. It further held there was no fixed-place PE nor dependent agent PE on the record, and mere remote support/coordination was insufficient; consequently the receipts were not taxable in India and no TDS obligation arose, so section 40(a)(i) invocation was unwarranted and the appeal was allowed.
ITAT considered whether cross-border corporate service payments attracted TDS under section 195 by examining classification as fees for technical services and existence of a permanent establishment. The tribunal found the services did not make available technical knowledge, experience, skill, know-how or processes, so the payments did not qualify as FTS under the IndiaSingapore DTAA and were at best business profits. It further held there was no fixed-place PE nor dependent agent PE on the record, and mere remote support/coordination was insufficient; consequently the receipts were not taxable in India and no TDS obligation arose, so section 40(a)(i) invocation was unwarranted and the appeal was allowed.
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