Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
