Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Section 10(23C) exemption for the relevant year did not require return filing by entities outside the categories expressly covered by the Twentieth Proviso. A later amendment imposing a return-filing condition for specified entities could not be applied to that year. Where the revenue authorities did not find that the substantive exemption conditions were unmet, non-filing of a return alone could not defeat the claim. Exemption was consequently directed to be granted in accordance with law, and the income assessed under "Income from Other Sources" was deleted.
Section 10(23C) exemption for the relevant year did not require return filing by entities outside the categories expressly covered by the Twentieth Proviso. A later amendment imposing a return-filing condition for specified entities could not be applied to that year. Where the revenue authorities did not find that the substantive exemption conditions were unmet, non-filing of a return alone could not defeat the claim. Exemption was consequently directed to be granted in accordance with law, and the income assessed under "Income from Other Sources" was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
