Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
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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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