Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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Non-reporting of an international transaction may attract penalty under section 271AA, but a bona fide belief based on reasonable cause can exclude liability where the transaction has no effective nexus with an Indian project office or permanent establishment, no related income is attributed to India, and the transaction is accepted at arm's length. The notes state that penalty for a Korean sale of raw materials to an Indian associated enterprise was deleted on this basis. They further explain that appellate enhancement cannot introduce transactions outside the scope of the original penalty proceedings. Enhancement relating to guarantee fees and trade affairs services was therefore unsustainable because initiation had concerned only the raw-material sale.
Non-reporting of an international transaction may attract penalty under section 271AA, but a bona fide belief based on reasonable cause can exclude liability where the transaction has no effective nexus with an Indian project office or permanent establishment, no related income is attributed to India, and the transaction is accepted at arm's length. The notes state that penalty for a Korean sale of raw materials to an Indian associated enterprise was deleted on this basis. They further explain that appellate enhancement cannot introduce transactions outside the scope of the original penalty proceedings. Enhancement relating to guarantee fees and trade affairs services was therefore unsustainable because initiation had concerned only the raw-material sale.
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