Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Commission paid to a foreign director for marketing and sourcing export orders was held taxable under reverse charge because the director supplied services from outside India, the recipient was in India, and the place of supply under Section 13(2) was India, making it an import of services. Commission paid to foreign marketing agents was held not taxable because they were treated as intermediary services and, under Section 13(8), the place of supply was outside India, so the import of services condition failed. Charges paid to foreign clearing and forwarding agents for arrival, customs clearance and terminal handling services rendered abroad were held taxable under reverse charge as import of services.
Commission paid to a foreign director for marketing and sourcing export orders was held taxable under reverse charge because the director supplied services from outside India, the recipient was in India, and the place of supply under Section 13(2) was India, making it an import of services. Commission paid to foreign marketing agents was held not taxable because they were treated as intermediary services and, under Section 13(8), the place of supply was outside India, so the import of services condition failed. Charges paid to foreign clearing and forwarding agents for arrival, customs clearance and terminal handling services rendered abroad were held taxable under reverse charge as import of services.
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