Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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