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No TDS on rental payment made by co. on behalf of directors if recipient had no deduction certificate u/s 197
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Corporate Tax
No TDS on rental payment made by co. on behalf of directors if recipient had no deduction certificate u/s 197
Posted on
on
September 11, 2017
Tenet Tax Daily August 28 2017
By
tenettax-team
Corporate Tax
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In absence of any positive and substantive material to effect that services had been rendered by employees of branch office of assessee, royalty income earned by assessee on account of technical agreement with another company was not effectively connected with branch office of assessee, and therefore, same was chargeable to tax as ‘royalty’ income as per article 13(1) and (2) of India-Italy DTAA
Sec. 263 revision was valid if assessee failed to substantiate source of cash deposit with any evidence
