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Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Certificate under Section 195 was ordered rectified: a previously issued 5.25% certificate is directed to be treated as a Nil rate certificate and the competent authority must issue an amended Nil rate certificate within seven days on production of this order. Further directions require future Nil rate certificates for FY 2025 26 and subsequent years to be issued within 30 days of application, subject to a recorded finding that the applicant has a Permanent Establishment in India; such an adverse finding requires prior notice. Applicants must make full and true disclosure in annual applications.
Certificate under Section 195 was ordered rectified: a previously issued 5.25% certificate is directed to be treated as a Nil rate certificate and the competent authority must issue an amended Nil rate certificate within seven days on production of this order. Further directions require future Nil rate certificates for FY 2025 26 and subsequent years to be issued within 30 days of application, subject to a recorded finding that the applicant has a Permanent Establishment in India; such an adverse finding requires prior notice. Applicants must make full and true disclosure in annual applications.
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TaxTMI 
TaxTMI 
