Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
The text addresses applications under section 197 for determination of withholding tax rate, emphasising that the competent authority must consider the nature of transactions and relevant material before fixing a NIL or other rate; the court declined to direct issuance of a NIL certificate because no authority had examined transaction nature. The court quashed the earlier administrative order and certificate and directed reissuance of a certificate at a lower rate so the assessee must file returns and may be subjected to scrutiny under CBDT criteria; it also ordered time limits for issuing the certificate and for future applications to be decided within the prescribed period.
The text addresses applications under section 197 for determination of withholding tax rate, emphasising that the competent authority must consider the nature of transactions and relevant material before fixing a NIL or other rate; the court declined to direct issuance of a NIL certificate because no authority had examined transaction nature. The court quashed the earlier administrative order and certificate and directed reissuance of a certificate at a lower rate so the assessee must file returns and may be subjected to scrutiny under CBDT criteria; it also ordered time limits for issuing the certificate and for future applications to be decided within the prescribed period.
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