Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
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ITAT held that receipts characterised as fees for technical services could not be taxed in India under the residuary Article 22 of the India-Thailand DTAA merely because the treaty lacks a specific FTS article; such income was treated as business income, and in the absence of a permanent establishment in India, the related addition was deleted. It remitted the section 234A interest issue to the Assessing Officer for verification of the actual filing date and directed that no interest would arise if the return was filed within the prescribed or extended time, with section 234B interest consequential. The challenge to initiation of penalty under section 270A was dismissed as premature.
ITAT held that receipts characterised as fees for technical services could not be taxed in India under the residuary Article 22 of the India-Thailand DTAA merely because the treaty lacks a specific FTS article; such income was treated as business income, and in the absence of a permanent establishment in India, the related addition was deleted. It remitted the section 234A interest issue to the Assessing Officer for verification of the actual filing date and directed that no interest would arise if the return was filed within the prescribed or extended time, with section 234B interest consequential. The challenge to initiation of penalty under section 270A was dismissed as premature.
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