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Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
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Under the Sabka Vishwas Scheme, timely payment and withdrawal of pending litigation are substantive conditions for a discharge certificate, while notifying the designated committee of withdrawal is procedural. Where payment was made within time and withdrawal was sought while the Scheme operated, delayed court listing during the COVID-19 period cannot defeat relief. Portal closure or delayed proof of withdrawal does not justify refusal of the certificate or revival of the demand. The declaration must be processed manually and the discharge certificate issued once the substantive conditions are met.
Under the Sabka Vishwas Scheme, timely payment and withdrawal of pending litigation are substantive conditions for a discharge certificate, while notifying the designated committee of withdrawal is procedural. Where payment was made within time and withdrawal was sought while the Scheme operated, delayed court listing during the COVID-19 period cannot defeat relief. Portal closure or delayed proof of withdrawal does not justify refusal of the certificate or revival of the demand. The declaration must be processed manually and the discharge certificate issued once the substantive conditions are met.
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