TDS u/s 195 - withhold tax on the payments made to the MRI ...

Tax Withholding Dispute u/s 195: Nature of Relationship Between Assessee and MRI Company to be Re-examined.

January 6, 2023

Case Laws Income Tax AT

TDS u/s 195 - withhold tax on the payments made to the MRI company - assessee contended that it is acting as a collection agent on its behalf - Neither the assessee nor the lower authorities have been able to bring on record the correct facts as to the relationship between the assessee and the MRI company viz., whether it is a principal-agent or principal - principal relationship. Hence, the contentions raised by the assessee before us remains unsubstantiated and unverified. - Matter restored back - AT

View Source

← Previous Next →

TDS u/s 195 - withhold tax on the payments made to the MRI ...

Tax Withholding Dispute u/s 195: Nature of Relationship Between Assessee and MRI Company to be Re-examined.

January 6, 2023

Case Laws Income Tax AT

You may also like:

Application u/s 197 - reduction of withholding tax - petitioner had sought a certificate, at “NIL” rate of tax - request to issue certificate at lower was rejected -...

TDS u/s 195 - withholding tax deducted at source (TDS) - Considering that the nature of these proceedings is confined to withholding of tax, and that the financial year...

TDS u/s 195 - withholding demands under section 201 - A tax withholding liability, particularly under section 195, is a vicarious liability and its survival entirely...

TDS u/s 195 - section 195 itself is quite explicit in its language while providing withholding of tax in respect of any payment, which is chargeable to tax in India....

TDS u/s 195 - software expenses - the arrangement of the assessee company with its AE is of purchase of computer software at agreed price i.e. sale price to the Indian...

Writ petitions challenged the 4% withholding tax rate u/s 195 on receipts asserted as business income u/s 9(1)(i), despite the petitioner having withheld tax at 1.5%....

Withholding tax credit deducted by US based subsidiary of the assessee company in USA on payment of interest loan - Indo-US DTAA - If the TDS certificate is produced by...

The ITAT examined two issues: (1) Tax deduction at source (TDS) u/s 195 on payments to seconded employees, and (2) disallowance of technology fees paid to the parent...

Refund of TDS - Rate of Withholding tax (TDS) - assessee deducting tax at 20% instead of 15% u/s 195 - - assessee’s claim for refund of tax deducted at source @ 5% on...

TDS u/s 195 - interest u/s. 201(IA) - The levy of interest to compensate for the delay in realization of taxes, in the event of the taxability of subject income being...

TDS u/s 195 - nature of 'referral fee' paid outside India - No services were rendered in India by these two companies for facilitating the investment in the assessee...

TDS u/s 192 or 195 - salary and other allowances of expatriate employees - As perused the TDS certificates, Forms 15CA and 15CB, tax deducted by the assessee and all...

Withholding Tax (TDS) u/s 195 - payment of distribution fees - treatment as Royalty / FTS - DAPE [Dependent Agent Permanent Establishment - the Assessee cannot be...

The ITAT addressed various issues: disallowance u/s 40(a)(ia) for year-end provisions, deduction u/s 10AA for interest income, TDS u/s 195 for subscription fees, foreign...

TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the...

Quick Updates: