Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
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Virtual performance of services by e-mail, video conferencing or conference calls was not treated as physical rendition in India for withholding tax purposes, because no specific provision in law or the DTAA deemed such services to be physically rendered in India. The Court also upheld refusal of a nil certificate under Section 197, reading Rule 28AA to require consideration of existing and estimated tax liability, including prior assessed liability; subsisting adverse findings in the petitioner's own case justified rejection. It declined to decide the treaty-based non-taxability claim on merits in writ jurisdiction, as the same issue was already pending in appellate proceedings.
Virtual performance of services by e-mail, video conferencing or conference calls was not treated as physical rendition in India for withholding tax purposes, because no specific provision in law or the DTAA deemed such services to be physically rendered in India. The Court also upheld refusal of a nil certificate under Section 197, reading Rule 28AA to require consideration of existing and estimated tax liability, including prior assessed liability; subsisting adverse findings in the petitioner's own case justified rejection. It declined to decide the treaty-based non-taxability claim on merits in writ jurisdiction, as the same issue was already pending in appellate proceedings.
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