Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Application for a certificate at nil tax rate was directed to be granted on treaty-based grounds, holding that the competent authority must decide under domestic law while giving due regard to the India-USA tax treaty and must not be driven by revenue targets; the impugned refusal was quashed and a nil-rate certificate ordered within 15 days. Future-year certificates must be issued within 30 days of application unless the authority records a finding of a Permanent Establishment after issuing notice; applicants must disclose all material facts and cooperate with any PE inquiry.
Application for a certificate at nil tax rate was directed to be granted on treaty-based grounds, holding that the competent authority must decide under domestic law while giving due regard to the India-USA tax treaty and must not be driven by revenue targets; the impugned refusal was quashed and a nil-rate certificate ordered within 15 days. Future-year certificates must be issued within 30 days of application unless the authority records a finding of a Permanent Establishment after issuing notice; applicants must disclose all material facts and cooperate with any PE inquiry.
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