Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Foreign exchange gain from realization of export proceeds for IT/ITES services rendered to associated enterprises was treated as operating income under TNMM, because it arose on revenue account in the normal course of business; the Assessing Officer was directed to verify this linkage, and the remaining transfer pricing grounds were left academic. Donation to Odisha State Disaster Management Authority was held eligible for deduction under section 80G despite being part of CSR expenditure, as there is no general bar outside the statutory exclusions. The foreign tax credit claim under section 90 was restored for verification and consequential grant in accordance with law.
Foreign exchange gain from realization of export proceeds for IT/ITES services rendered to associated enterprises was treated as operating income under TNMM, because it arose on revenue account in the normal course of business; the Assessing Officer was directed to verify this linkage, and the remaining transfer pricing grounds were left academic. Donation to Odisha State Disaster Management Authority was held eligible for deduction under section 80G despite being part of CSR expenditure, as there is no general bar outside the statutory exclusions. The foreign tax credit claim under section 90 was restored for verification and consequential grant in accordance with law.
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