Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
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...
The article determines that the applicant institute qualifies as a specified person required to deduct TDS under Section 51 read with Notification No.50/2018 CT because substantial regulatory control (not day to day operational control) by the Central Government exists; Supreme Court precedent overrides administrative circulars. It clarifies that "control" denotes regulatory authority sufficient to trigger notification coverage. On contractual threshold, where supply is continuous and performed in parts, the contract as a whole-aggregating all part invoices-determines the threshold for TDS; separate contracts are assessed individually. Outcome: the institute is liable to deduct TDS.
The article determines that the applicant institute qualifies as a specified person required to deduct TDS under Section 51 read with Notification No.50/2018 CT because substantial regulatory control (not day to day operational control) by the Central Government exists; Supreme Court precedent overrides administrative circulars. It clarifies that "control" denotes regulatory authority sufficient to trigger notification coverage. On contractual threshold, where supply is continuous and performed in parts, the contract as a whole-aggregating all part invoices-determines the threshold for TDS; separate contracts are assessed individually. Outcome: the institute is liable to deduct TDS.
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