Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
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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