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...
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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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