Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Attachment of Pre Offence Mortgaged Property remains possible under PMLA; secured creditors may pursue statutory claim and seek auction with undertaki...
Petitioner, a non-resident US company, sought a withholding-tax certificate. The court held on prima facie review that services described as Matching Solution qualify for issuance of a NIL-rate withholding certificate and directed the competent authority to issue such certificate for the current and subsequent years within prescribed timelines; the authority may later revoke or refuse if it records a finding of Permanent Establishment or taxable transactions in India after issuing notice. For the separate Support Services agreement the court directed withholding to continue for the year and left substantive determination for appropriate proceedings. Annual full-disclosure by petitioner required.
Petitioner, a non-resident US company, sought a withholding-tax certificate. The court held on prima facie review that services described as Matching Solution qualify for issuance of a NIL-rate withholding certificate and directed the competent authority to issue such certificate for the current and subsequent years within prescribed timelines; the authority may later revoke or refuse if it records a finding of Permanent Establishment or taxable transactions in India after issuing notice. For the separate Support Services agreement the court directed withholding to continue for the year and left substantive determination for appropriate proceedings. Annual full-disclosure by petitioner required.
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