Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Offshore principal-to-principal sales of CKD kits, raw materials, spare parts and CBU cars may fall outside Indian taxation where contracts are concluded abroad and no further sales activity occurs in India. Mere ownership of an Indian subsidiary does not create a fixed place permanent establishment where the foreign enterprise has no right to use its premises, no place of management there, and conducts no operations in India. An Indian entity acting only as a communication channel, without contract-concluding authority or habitual order securing role, is not a dependent agent. In the absence of a permanent establishment, no profits are attributable to India under the treaty.
Offshore principal-to-principal sales of CKD kits, raw materials, spare parts and CBU cars may fall outside Indian taxation where contracts are concluded abroad and no further sales activity occurs in India. Mere ownership of an Indian subsidiary does not create a fixed place permanent establishment where the foreign enterprise has no right to use its premises, no place of management there, and conducts no operations in India. An Indian entity acting only as a communication channel, without contract-concluding authority or habitual order securing role, is not a dependent agent. In the absence of a permanent establishment, no profits are attributable to India under the treaty.
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