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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For Section 44B, "carriage" of passengers by a foreign shipping enterprise extends beyond transportation between two ports. A round cruise voyage may remain passenger carriage where passengers can disembark at intermediate ports and the principal receipts arise from cabin and transport fares. On-board hospitality and entertainment are ancillary to the voyage and do not, by themselves, remove cruise operations from the presumptive taxation scheme. The text states that the non-resident cruise operator's income was therefore computable under Section 44B at the prescribed presumptive rate, and the concurrent finding treating the activity as passenger carriage was affirmed.
For Section 44B, "carriage" of passengers by a foreign shipping enterprise extends beyond transportation between two ports. A round cruise voyage may remain passenger carriage where passengers can disembark at intermediate ports and the principal receipts arise from cabin and transport fares. On-board hospitality and entertainment are ancillary to the voyage and do not, by themselves, remove cruise operations from the presumptive taxation scheme. The text states that the non-resident cruise operator's income was therefore computable under Section 44B at the prescribed presumptive rate, and the concurrent finding treating the activity as passenger carriage was affirmed.
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