Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
RPA (Remote Pilot Aircraft) for military use defined to include drones/UAV/UAS; exemptions limited to specified defence imports with Joint Secretary c...
Transfer of going concern and transfer of input tax credit under GST allowed; exemption applies though interstate ledger transfers left to authorities...
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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