Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
Page of 4821
Press 'Enter' after typing page number.
6761 to 6780 of 96408 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Cross-charge payments made under a cost-sharing arrangement on a cost-to-cost basis, without markup, were held to be pure reimbursement and not income; mere charging of service tax did not alter that character, so no TDS liability arose and disallowance under section 40(a)(ia) was unwarranted. The court also held that the second proviso to section 40(a)(ia), as introduced by the Finance Act, 2012, is curative and operates retrospectively; where the resident payee had reported the income, paid tax, and the requisite certificate was furnished, the payer could not be treated as an assessee in default. The Revenue's appeal was dismissed.
Cross-charge payments made under a cost-sharing arrangement on a cost-to-cost basis, without markup, were held to be pure reimbursement and not income; mere charging of service tax did not alter that character, so no TDS liability arose and disallowance under section 40(a)(ia) was unwarranted. The court also held that the second proviso to section 40(a)(ia), as introduced by the Finance Act, 2012, is curative and operates retrospectively; where the resident payee had reported the income, paid tax, and the requisite certificate was furnished, the payer could not be treated as an assessee in default. The Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.