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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Interest paid by an Indian permanent establishment to its head office or overseas branches may be deducted in determining profits attributable to the permanent establishment under the treaty, although the corresponding receipt is treated as payment to self under domestic law. Transactions between a foreign enterprise and its Indian permanent establishment may be subject to transfer-pricing rules; guarantee commission adjustments should reflect only the difference between the arm's length rate and commission already recovered. Foreign-exchange forward contract gains retain capital character where the contracts hedge capital investments. Interest on an income-tax refund is not effectively connected with the permanent establishment and is taxable under the treaty interest article. A treaty tax-rate ceiling prevents surcharge and education cess from exceeding that ceiling.
Interest paid by an Indian permanent establishment to its head office or overseas branches may be deducted in determining profits attributable to the permanent establishment under the treaty, although the corresponding receipt is treated as payment to self under domestic law. Transactions between a foreign enterprise and its Indian permanent establishment may be subject to transfer-pricing rules; guarantee commission adjustments should reflect only the difference between the arm's length rate and commission already recovered. Foreign-exchange forward contract gains retain capital character where the contracts hedge capital investments. Interest on an income-tax refund is not effectively connected with the permanent establishment and is taxable under the treaty interest article. A treaty tax-rate ceiling prevents surcharge and education cess from exceeding that ceiling.
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