Section 40(a)(i) – Where assessee is held not liable to deduct TDS, assessee cannot be treated as assessee in default if payee foreign company is liable to tax in reassessment.
Van Oord Acz India (P.) Ltd. v. CIT – [2023] 149 taxmann.com 38 (SC).
CBDT signs 95 Advance Pricing agreements in FY 2022-23; highest ever APA signing since launch.
Press Release dated 31-3-2023.
No TP addition if shift from floating to fixed interest rate was to protect business from adverse floating rates.
BG Exploration & Production India Ltd. v. DCIT – [2023] 148 taxmann.com 272 (Delhi Trib.).
Section 80IA – SLP dismissed against impugned order of HC that where by virtue of section 79 business loss of assessee prior to assessment year 2001-02 had already lapsed, same could not be notionally carried forward and set off against profits and gains of assesses business for AY 2005-06 under consideration in computing deduction u/s 80IA(1).
ACIT v. Vodafone Essar Gujarat Ltd. – [2023] 149 taxmann.com 1 (SC).
The Finance Act, 2023 received assent of the President on 31-3-2023.
CBDT notifies procedure for filing of application in Form 15C/15D for grant of ‘nil’ TDS Certificate u/s 195.
Notification No. 1/2023, dated 29-3-2023.