The April 2015 issue of Direct Tax Amicus features an article on compelling a non-resident to seek PAN which discusses two different decisions of the Tribunal with differing views on whether tax could be deducted at the rate prescribed in a treaty even when the non-resident does not have a PAN. The notification issued by CBDT on Income Computation and Disclosure Standards for the purpose of calculating income chargeable to income-tax under profits and gains of business or profession and a circular clarifying that taxation of dividend income declared by foreign company outside India are covered under Circular and Notification section of this issue. The Supreme Court order on similar treatment of the exporters having turnover less than and more than Rs. 10 crore, the tribunal decision that tax need not to be deducted on subsequent payment on account of foreign exchange loss, and Supreme Court decision regarding claiming of deduction under Section 80HHC are some of the case laws covered in Ratio Decidendi section.
April, 2015/Issue-09