Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
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GIA India was treated as an independent entity and, on the Tribunal's factual findings accepted by the HC, no fixed place, service or agency PE of GIA US arose in India under Article 5 of the India-US DTAA. On royalty, the Court applied the real income principle and the APA framework to hold that only the royalty ultimately retained by GIA US after refund of the excess amount could be taxed in India under Article 12. The transfer pricing recomputation provisions invoked by the Revenue were held inapplicable because the arm's length price was governed by the APA and the refund had already been reflected in GIA India's tax position.
GIA India was treated as an independent entity and, on the Tribunal's factual findings accepted by the HC, no fixed place, service or agency PE of GIA US arose in India under Article 5 of the India-US DTAA. On royalty, the Court applied the real income principle and the APA framework to hold that only the royalty ultimately retained by GIA US after refund of the excess amount could be taxed in India under Article 12. The transfer pricing recomputation provisions invoked by the Revenue were held inapplicable because the arm's length price was governed by the APA and the refund had already been reflected in GIA India's tax position.
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