CA Certificate has no decisive impact on taxability of non-residents income

DCIT Vs Rediff.com India Limited (ITAT Mumbai) – Certificate issued by a Chartered Accountant has no decisive impact on tax ability of income in the hands of a non-resident but it is only prima-facie evidence about the tax ability. In order to disallow the payments under Section 40(a)(i) of the Act, the AO needs to examine whether the recipient has a tax liability in India and that aspect can be examined only when all the relevant details were duly furnished by the taxpayer. However, a certificate issued by a CA could not be considered as a conclusive document while determining tax lia...