Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
Validity of a tax withholding certificate under Section 197 was challenged; the court held that where factual and legal conditions remain unchanged from prior years in which nil-rate certificates were granted, the competent authority cannot substitute a 10% withholding rate. The court found prior tribunal and Supreme Court findings attributing a portion of revenue to the Indian PE and that such attribution was absorbed by distributor remuneration to be final, rejected the respondent's reliance on a subsequent demand as a basis for a higher rate, quashed the 10% certificate and directed issuance of a nil-rate certificate for AY 2026-27 within fifteen days.
Validity of a tax withholding certificate under Section 197 was challenged; the court held that where factual and legal conditions remain unchanged from prior years in which nil-rate certificates were granted, the competent authority cannot substitute a 10% withholding rate. The court found prior tribunal and Supreme Court findings attributing a portion of revenue to the Indian PE and that such attribution was absorbed by distributor remuneration to be final, rejected the respondent's reliance on a subsequent demand as a basis for a higher rate, quashed the 10% certificate and directed issuance of a nil-rate certificate for AY 2026-27 within fifteen days.
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