Non-resident payment taxability permits withholding only on the chargeable proportion after examination under domestic law and applicable treaty. Rule 214 requires a payer seeking determination of the proportion of a non-resident payment chargeable to tax to apply in Form No. 129. The Assessing ... Summary
Non-resident payment taxability permits withholding only on the chargeable proportion after examination under domestic law and applicable treaty.
Rule 214 requires a payer seeking determination of the proportion of a non-resident payment chargeable to tax to apply in Form No. 129. The Assessing Officer examines taxability under the Income-tax Act, 2025 and the applicable Double Taxation Avoidance Agreement, determines the taxable proportion where the entire payment is not chargeable, and issues a certificate for tax deduction. The certificate is confined to the named non-resident and specified tax-year period, may be cancelled before expiry, and may be renewed through a fresh application after expiry or within three months before it.
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