Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Challenge concerned issuance of a withholding tax certificate at 15% instead of a requested NIL certificate for a UK-incorporated company under Section 197; the text emphasises that orders under Section 197 operate as advance tax and are refundable if not exigible, but that accepting Revenue's position would defeat the provision's purpose. The account notes significant delay between application and order, during which tax was deducted. The operative outcome recorded is quashing of the impugned order and direction to issue a NIL-rate certificate for the relevant assessment year within fifteen days and to continue issuing annual NIL certificates within thirty days of future applications.
Challenge concerned issuance of a withholding tax certificate at 15% instead of a requested NIL certificate for a UK-incorporated company under Section 197; the text emphasises that orders under Section 197 operate as advance tax and are refundable if not exigible, but that accepting Revenue's position would defeat the provision's purpose. The account notes significant delay between application and order, during which tax was deducted. The operative outcome recorded is quashing of the impugned order and direction to issue a NIL-rate certificate for the relevant assessment year within fifteen days and to continue issuing annual NIL certificates within thirty days of future applications.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
