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...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee's own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at dealer premises was upheld, and fresh bad debt and foreign tax credit claims were remanded. Duty drawback taxed on accrual basis was deleted on consistency.
Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee's own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at dealer premises was upheld, and fresh bad debt and foreign tax credit claims were remanded. Duty drawback taxed on accrual basis was deleted on consistency.
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