The bench directed that the interim amount deposited, if any , made during the writ as per the directions of High Court shall be treated as compliance with the pre-deposit requirement under Section 112(8).

Mere non-reflection of income in ST-3 returns, without establishing taxability, cannot be equated with deliberate suppression’ stated the appellate tribunal.

The court rules that a “virtual service permanent establishment” is not recognised under the India-UK tax treaty and cannot be used to justify withholding tax.