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...
Routine back-office support services were not royalty under the applicable DTAAs because the agreements showed no grant of rights in copyright, patents, designs, secret processes or equipment, and the domestic Act could not override the more beneficial treaty. The same receipts were also treated as business profits and, in the absence of a permanent establishment in India, not taxable in India. Claims against fee for delayed return filing and interest for delayed filing were remanded for verification of whether the returns were filed within time. The challenge to initiation of penalty under the anti-underreporting provision was rejected as premature.
Routine back-office support services were not royalty under the applicable DTAAs because the agreements showed no grant of rights in copyright, patents, designs, secret processes or equipment, and the domestic Act could not override the more beneficial treaty. The same receipts were also treated as business profits and, in the absence of a permanent establishment in India, not taxable in India. Claims against fee for delayed return filing and interest for delayed filing were remanded for verification of whether the returns were filed within time. The challenge to initiation of penalty under the anti-underreporting provision was rejected as premature.
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