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...
The enhanced tax rate under section 115BBE, operative from 1 April 2017, applies prospectively and therefore covers surrendered income from excess stock and cash for Assessment Year 2019-20. As the amended provision was already in force for that year, surrendered income was taxable at the enhanced rate. Rectification under section 154 to correct the tax computation was sustained.
The enhanced tax rate under section 115BBE, operative from 1 April 2017, applies prospectively and therefore covers surrendered income from excess stock and cash for Assessment Year 2019-20. As the amended provision was already in force for that year, surrendered income was taxable at the enhanced rate. Rectification under section 154 to correct the tax computation was sustained.
Note: It is a system-generated summary and is for quick reference only.