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2007 (12) TMI 182 - HC - Income Tax
Petitioner, foreign company, non-resident - petitioner receives diamond grading & certification charges from Indian customers - Petitioner applied to AO to grant a certificate u/s 197(1) to receive impugned charges from customers without deduction of tax at source, which was denied by AO – since there is no transfer of technical skill etc. by petitioner & fees received do not fall within the expression “royalty” the action of AO in refusing the certificate u/s 195 was not in jurisdiction