Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Under Article 12 of the India-Netherlands DTAA, intra-group service and cost-recovery receipts were held not to be fees for technical services because the services did not satisfy the make available condition; the recipient was not shown to acquire technical knowledge, skill, know-how or processes for independent future use. The separate plea that the receipts were mere reimbursements or cost allocations was rejected following earlier years. Surcharge and cess beyond the treaty rate on royalty and fees for technical services were disallowed because the treaty caps tax at 10 per cent and Indian tax includes surcharge. Computation errors, interest under section 234B, TDS credit and refund adjustment issues were remitted for verification.
Under Article 12 of the India-Netherlands DTAA, intra-group service and cost-recovery receipts were held not to be fees for technical services because the services did not satisfy the make available condition; the recipient was not shown to acquire technical knowledge, skill, know-how or processes for independent future use. The separate plea that the receipts were mere reimbursements or cost allocations was rejected following earlier years. Surcharge and cess beyond the treaty rate on royalty and fees for technical services were disallowed because the treaty caps tax at 10 per cent and Indian tax includes surcharge. Computation errors, interest under section 234B, TDS credit and refund adjustment issues were remitted for verification.
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