Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Tax deduction at source on payments to non-residents arises only if the payment contains income chargeable to tax in India. A tax residency certificate affects access to treaty relief, but its absence does not itself establish a domestic tax charge. Commission for services performed outside India, without evidence of services or business operations in India, is not shown to be taxable in India; consequently, no tax deduction or related disallowance applies, subject to arithmetical verification. Form 15CB descriptions do not conclusively establish a payment's character, which must be determined from agreements, invoices and services rendered. A disallowance may remain where the taxpayer accepts the proposed variation and does not rebut it.
Tax deduction at source on payments to non-residents arises only if the payment contains income chargeable to tax in India. A tax residency certificate affects access to treaty relief, but its absence does not itself establish a domestic tax charge. Commission for services performed outside India, without evidence of services or business operations in India, is not shown to be taxable in India; consequently, no tax deduction or related disallowance applies, subject to arithmetical verification. Form 15CB descriptions do not conclusively establish a payment's character, which must be determined from agreements, invoices and services rendered. A disallowance may remain where the taxpayer accepts the proposed variation and does not rebut it.
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