https://www.taxtmi.com/caselaws?id=63064 A liberal, justice-oriented construction of "sufficient cause" was applied for condonation of delay where the assessee acted bona fide and the delay was explained by business collapse, management change, staff loss, related tax pendency and attempts to recover the tax through the non-resident payee; the delay was condoned. On the merits, remittances to the foreign company were found not chargeable to tax in India because the Revenue did not establish a taxable nexus, including a permanent establishment, and the earlier assessee-specific rulings were followed. The insistence on deduction of tax at source was therefore unjustified, and the payer's right of appeal under section 248 was recognised. en-us Mon, 31 Oct 2005 00:00:00 +0530 Tue, 09 Apr 2024 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63064 A liberal, justice-oriented construction of "sufficient cause" was applied for condonation of delay where the assessee acted bona fide and the delay was explained by business collapse, management change, staff loss, related tax pendency and attempts to recover the tax through the non-resident payee; the delay was condoned. On the merits, remittances to the foreign company were found not chargeable to tax in India because the Revenue did not establish a taxable nexus, including a permanent establishment, and the earlier assessee-specific rulings were followed. The insistence on deduction of tax at source was therefore unjustified, and the payer's right of appeal under section 248 was recognised. Case-Laws Income Tax Mon, 31 Oct 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63064