S. 245R : Advance rulings-Notice u/s. 143(2)-Whether the consideration for offshore supply of 4DX equipment to PVR under Strategic Alliance Agreement is liable to tax in India-Application admitted-DTAA-India-Korea. [S. 9(1)(i), 143(2), 245R(2), Art. 5, 12]
S. 245R : Advance rulings-Dividend to non-resident shareholders Dividend Distribution Tax (DDT)-DTAA-India-France. [Art. 11, 115-O, 245R(2), Art. 11]
S. 245R : Advance rulings-Salaries paid to seconded employees in India whether qualify as non-resident-Credit for deduction of tax at source-DTAA-India-Japan. [Art. 15(1), S. 192]
S. 245R : Advance rulings-Capital gains tax-Transfer of shares on receipt of dividend in kind-Application is admitted-DTAA-India-Luxembourg. [Art. 10, 13]
S. 245R : Advance rulings-Domestic companies-Tax on distributed profits-Beneficial provision of DTAA-DTAA-India-Singapore. [S. 1150, 245R(2), Art. 10]
S. 240 : Refund-Appeal-No part of the refund can be withheld in relation to the income-tax demands which are ether quashed by appellate authority or Tribunal or stayed. [S. 244A]
S. 195 : Deduction at source-Non-resident-Other sums-seconded employees-Expenses reimbursed-Cannot be considered as fees for technical services-Not liable to deduct tax at source-DTAA-India-UK. [S. 9(1)(vii), 195(2), 201(1)].
S. 194H : Deduction at source-Commission or brokerage-Trade discount-Newspaper vendors and advertising agencies-Not in the nature of commission-Not liable to deduct tax at source. [S. 194C, 40(a)(ia)]
S. 147 : Reassessment-Protective assessment-Search and seizure-Statement of third party-No incriminating material was found against the assessee-Order Tribunal quashing the reassessment was affirmed. [S. 132, 148, 260A]
S. 147 : Reassessment-Search in third party premises-Sale of land-Unexplained investment-Return was not filed-Reassessment notice issued after analysing voluminous material collected by revenue during search-Reassessment notice is held to be valid-Search undertaken prior to 1-6-2015-Argument that proceedings should have been initiated u/s 153C and not under section 148 was not accepted. [S. 69A, 132, 133A, 148, 153C, Art. 226]