https://www.taxtmi.com/caselaws?id=216658 Finality attached to an advance ruling does not exclude writ review under Article 226; interference remains confined to natural justice breaches, perversity, patent illegality, bias, malice, or other legal infirmity. On that basis, the writ petition was maintainable. The ruling also states that reimbursement for seconded employees, assessed under the contractual arrangement and factual findings, could be treated as income in the hands of the recipient and attract tax deduction at source under section 195. However, the reasoning on DTAA classification was found incomplete and inconsistent, so that aspect was remitted for fresh consideration. en-us Tue, 09 Aug 2011 00:00:00 +0530 Tue, 18 Sep 2012 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216658 Finality attached to an advance ruling does not exclude writ review under Article 226; interference remains confined to natural justice breaches, perversity, patent illegality, bias, malice, or other legal infirmity. On that basis, the writ petition was maintainable. The ruling also states that reimbursement for seconded employees, assessed under the contractual arrangement and factual findings, could be treated as income in the hands of the recipient and attract tax deduction at source under section 195. However, the reasoning on DTAA classification was found incomplete and inconsistent, so that aspect was remitted for fresh consideration. Case-Laws Income Tax Tue, 09 Aug 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216658