Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Tax-residency relief for Indian seafarers unable to remain outside India during the COVID-19 pandemic was sought through quashing CBDT Circular No. 11 of 2020 and adoption of a compassionate tax policy. The proposed policy would grant at least sixty days' exemption to seafarers who spent more than 182 days in India during a financial year. Representations were directed to receive sympathetic consideration, with an appropriate decision requested within four weeks, without examination of merits.
Tax-residency relief for Indian seafarers unable to remain outside India during the COVID-19 pandemic was sought through quashing CBDT Circular No. 11 of 2020 and adoption of a compassionate tax policy. The proposed policy would grant at least sixty days' exemption to seafarers who spent more than 182 days in India during a financial year. Representations were directed to receive sympathetic consideration, with an appropriate decision requested within four weeks, without examination of merits.
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