Thanks Ashutosh Majumdar Sir...We were also of the same view, your observation further supported it.
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Discussion / Withholding Tax: Foreign Branches of Indian Banks
August 16, 2012, 03:27:01 PM
Respected members,
Topic is of withholding tax on interest payments to Foreign Branches of Indian Banks on ECB Borrwings. Following are the burning issues:-
1. What would be the residential status of "Foreign Branches of Indian Banks"?
2. Whether TDS is applicable u/s 195 or will be covered under the exemptions of section 194A?
Kindly share your view with the legal supporting (if any)...
Thanks & Regards...!!!
Topic is of withholding tax on interest payments to Foreign Branches of Indian Banks on ECB Borrwings. Following are the burning issues:-
1. What would be the residential status of "Foreign Branches of Indian Banks"?
2. Whether TDS is applicable u/s 195 or will be covered under the exemptions of section 194A?
Kindly share your view with the legal supporting (if any)...
Thanks & Regards...!!!
#3
Discussion / Re: Reopening beyound four years based on subsequnet clarification of CBDT is posil
August 11, 2012, 03:18:36 PM
Reopening beyond 4 years on basis of retrospective amendment not justified if assessee has not failed to disclose material facts: Ref Sadbhav Engineering vs. DCIT (Gujarat High Court)
#4
Discussion / Re: assessement u/s 143(3)
January 24, 2012, 03:22:02 PM
Assessing Officer cannot assess an income which is not taxable as per law though shown in return of income:- 15 taxmann.com 52 (Kolkata Tribunal)
The Department should not take advantage of the ignorance of the assessee :- CBDT Circular No. 14 (XL-35) of 1955, dt. 11th April, 1955.
The Department should not take advantage of the ignorance of the assessee :- CBDT Circular No. 14 (XL-35) of 1955, dt. 11th April, 1955.
#5
Discussion / Re: sec.40(ia) disallowance for non-payment of TDS
January 24, 2012, 03:11:10 PM
Instruction : F. No. 275/201/95-IT(B) on 29-1-1997 issued by CBDT
Where taxes have been paid by deductee-assessee
"The Board is of the view that no demand visulasied under section 201(1) of the Income-tax Act should be enforced after the tax deductor has satisfied the officer in charge of TDS that taxes have been paid by the deductee-assessee."
Where taxes have been paid by deductee-assessee
"The Board is of the view that no demand visulasied under section 201(1) of the Income-tax Act should be enforced after the tax deductor has satisfied the officer in charge of TDS that taxes have been paid by the deductee-assessee."
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