Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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Explanations 4 to 6 to section 9(1)(vi) were held to expand the definition of royalty and to operate prospectively from 01.04.2012, following the Supreme Court ruling in Engineering Analysis and the assessee's earlier case. On that basis, remittance for IPLC and related bandwidth services to a non-resident was not taxable as royalty for the years in question, so no obligation to deduct tax at source under section 195 arose. Consequently, disallowance under section 40(a)(i) and consequential action under section 201, including interest liability, could not be sustained. The Court also noted that the law does not require an impossible act, and the questions of law were answered for the assessee.
Explanations 4 to 6 to section 9(1)(vi) were held to expand the definition of royalty and to operate prospectively from 01.04.2012, following the Supreme Court ruling in Engineering Analysis and the assessee's earlier case. On that basis, remittance for IPLC and related bandwidth services to a non-resident was not taxable as royalty for the years in question, so no obligation to deduct tax at source under section 195 arose. Consequently, disallowance under section 40(a)(i) and consequential action under section 201, including interest liability, could not be sustained. The Court also noted that the law does not require an impossible act, and the questions of law were answered for the assessee.
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