Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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...
Under the India-Netherlands DTAA, executive search services that are separate from a licensing arrangement and do not make available technical knowledge, skill, know-how or processes are addressed as neither fees for technical services nor royalty. The note also distinguishes managerial services from treaty-defined technical services, while requiring examination of the specific services under a shared-services agreement. Reimbursements of actual expenses without a profit element are treated separately from fees for technical services. Interest on income-tax refunds is subject to the treaty interest provision, and tax on treaty-covered income cannot exceed the treaty-prescribed rate, including through surcharge and cess. Tax deducted at source credit remains subject to factual verification.
Under the India-Netherlands DTAA, executive search services that are separate from a licensing arrangement and do not make available technical knowledge, skill, know-how or processes are addressed as neither fees for technical services nor royalty. The note also distinguishes managerial services from treaty-defined technical services, while requiring examination of the specific services under a shared-services agreement. Reimbursements of actual expenses without a profit element are treated separately from fees for technical services. Interest on income-tax refunds is subject to the treaty interest provision, and tax on treaty-covered income cannot exceed the treaty-prescribed rate, including through surcharge and cess. Tax deducted at source credit remains subject to factual verification.
Note: It is a system-generated summary and is for quick reference only.
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