Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Foreign tax credit for overseas legal and consultancy receipts is examined under the India-Japan DTAA and Rule 128. The notes state that Article 14 on independent personal services applies to individuals, while the Article 12(4) exclusion for professional services is confined to payments made to individuals; therefore, a partnership firm's Japanese legal-service receipts are not excluded from foreign tax credit on the basis that Article 14 exclusively governs them. Where gross overseas receipts are included in Indian taxable income and supported by Form 67 and authenticated foreign tax-deduction certificates, Rule 128 contains no stated restriction on credit for overseas taxes withheld.
Foreign tax credit for overseas legal and consultancy receipts is examined under the India-Japan DTAA and Rule 128. The notes state that Article 14 on independent personal services applies to individuals, while the Article 12(4) exclusion for professional services is confined to payments made to individuals; therefore, a partnership firm's Japanese legal-service receipts are not excluded from foreign tax credit on the basis that Article 14 exclusively governs them. Where gross overseas receipts are included in Indian taxable income and supported by Form 67 and authenticated foreign tax-deduction certificates, Rule 128 contains no stated restriction on credit for overseas taxes withheld.
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