Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Attachment of Pre Offence Mortgaged Property remains possible under PMLA; secured creditors may pursue statutory claim and seek auction with undertaki...
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Legal services rendered by the partnership were treated as professional services, not fees for technical services; receipts from Indian engagements could not be taxed under section 9(1)(vii), and the related addition was deleted. The Tribunal also held that a UK partnership was fiscally transparent under UK law, so treaty protection under the India-UK DTAA extends only to the extent the income is taxed in the UK as income of a resident. Non-UK resident partners could not invoke the India-UK DTAA merely by being partners in the firm; their taxability had to be examined under the DTAAs of their respective countries of residence. The matter was remanded to the Assessing Officer for that limited examination.
Legal services rendered by the partnership were treated as professional services, not fees for technical services; receipts from Indian engagements could not be taxed under section 9(1)(vii), and the related addition was deleted. The Tribunal also held that a UK partnership was fiscally transparent under UK law, so treaty protection under the India-UK DTAA extends only to the extent the income is taxed in the UK as income of a resident. Non-UK resident partners could not invoke the India-UK DTAA merely by being partners in the firm; their taxability had to be examined under the DTAAs of their respective countries of residence. The matter was remanded to the Assessing Officer for that limited examination.
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