Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4788
Join Channel
TaxTMI 
