Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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The India-Sri Lanka tax treaty is amended to expressly prevent non-taxation or reduced taxation arising from tax evasion, avoidance and treaty-shopping arrangements that indirectly benefit third-State residents. It also introduces a principal purpose test: treaty benefits may be denied where, considering all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of an arrangement or transaction, unless granting it accords with the object and purpose of the relevant treaty provisions. The Protocol entered into force on 19 June 2026 and applies in India to income derived in fiscal years beginning on or after 1 April 2027.
The India-Sri Lanka tax treaty is amended to expressly prevent non-taxation or reduced taxation arising from tax evasion, avoidance and treaty-shopping arrangements that indirectly benefit third-State residents. It also introduces a principal purpose test: treaty benefits may be denied where, considering all relevant facts and circumstances, obtaining the benefit was one of the principal purposes of an arrangement or transaction, unless granting it accords with the object and purpose of the relevant treaty provisions. The Protocol entered into force on 19 June 2026 and applies in India to income derived in fiscal years beginning on or after 1 April 2027.
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