https://www.taxtmi.com/caselaws?id=414318 Section 163 proceedings treating a joint venture as agent of a foreign collaborator were found unsustainable where the collaborator had a permanent establishment in India, operated under Indian regulatory permissions and filings, and tax had already been deducted at source on payments to it. The Tribunal noted that the earlier proceedings did not contain any binding direction to initiate section 163 action, and the Assessing Officer therefore lacked legal support for invoking the provision against the joint venture. The invocation of section 163 was held invalid, and the assessee succeeded. en-us Thu, 28 Oct 2021 00:00:00 +0530 Tue, 02 Nov 2021 09:29:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414318 Section 163 proceedings treating a joint venture as agent of a foreign collaborator were found unsustainable where the collaborator had a permanent establishment in India, operated under Indian regulatory permissions and filings, and tax had already been deducted at source on payments to it. The Tribunal noted that the earlier proceedings did not contain any binding direction to initiate section 163 action, and the Assessing Officer therefore lacked legal support for invoking the provision against the joint venture. The invocation of section 163 was held invalid, and the assessee succeeded. Case-Laws Income Tax Thu, 28 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414318