Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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.
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