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...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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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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