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...
Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.
Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.
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