Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Annual election between the Income-tax Act and the applicable tax treaty permits an assessee to select the more beneficial regime independently for each assessment year, with no identified bar on changing that option across years. Where treaty treatment under the India-Mauritius DTAA renders capital gains non-taxable in India, earlier short-term capital losses validly carried forward need not be set off against those exempt gains. Those losses may therefore continue to be carried forward. The Revenue's challenge to further carry forward of the losses failed on merits, while the reassessment challenge became infructuous.
Annual election between the Income-tax Act and the applicable tax treaty permits an assessee to select the more beneficial regime independently for each assessment year, with no identified bar on changing that option across years. Where treaty treatment under the India-Mauritius DTAA renders capital gains non-taxable in India, earlier short-term capital losses validly carried forward need not be set off against those exempt gains. Those losses may therefore continue to be carried forward. The Revenue's challenge to further carry forward of the losses failed on merits, while the reassessment challenge became infructuous.
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