Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Under the retrospective amendment to sections 144C, 153 and 153B, the limitation periods under sections 153 and 153B apply only until the draft assessment order is forwarded. Thereafter, the Dispute Resolution Panel process and the Assessing Officer's finalisation operate under separate timelines, so a limitation objection to the final assessment order does not succeed. Buying agency services involving vendor identification, order placement, quality checks, logistics coordination and related procurement support are characterised as commercial agency functions rather than managerial, technical or consultancy services under Article 12(4) of the India-Switzerland DTAA. The resulting receipts remain business income and, absent a permanent establishment in India, are not taxable in India; the fees-for-technical-services addition is deleted, with interest consequential.
Under the retrospective amendment to sections 144C, 153 and 153B, the limitation periods under sections 153 and 153B apply only until the draft assessment order is forwarded. Thereafter, the Dispute Resolution Panel process and the Assessing Officer's finalisation operate under separate timelines, so a limitation objection to the final assessment order does not succeed. Buying agency services involving vendor identification, order placement, quality checks, logistics coordination and related procurement support are characterised as commercial agency functions rather than managerial, technical or consultancy services under Article 12(4) of the India-Switzerland DTAA. The resulting receipts remain business income and, absent a permanent establishment in India, are not taxable in India; the fees-for-technical-services addition is deleted, with interest consequential.
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