Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Tax treaty exemption for operation of airline and cargo services was held applicable, the competent authority's issuance of a certificate at a reduced withholding rate rested on an incorrect belief about outstanding assessments and thus reflected non-application of mind and inconsistent administration; because assessments showed no tax payable for the airline services, the HC set aside the impugned certificate and directed issuance of a NIL-rate certificate within seven days. The court noted taxable ground-handling and engineering services remain payable and were not affected.
Tax treaty exemption for operation of airline and cargo services was held applicable, the competent authority's issuance of a certificate at a reduced withholding rate rested on an incorrect belief about outstanding assessments and thus reflected non-application of mind and inconsistent administration; because assessments showed no tax payable for the airline services, the HC set aside the impugned certificate and directed issuance of a NIL-rate certificate within seven days. The court noted taxable ground-handling and engineering services remain payable and were not affected.
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