Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
MFN-based treaty benefits under the India-Netherlands DTAA require a notification under section 90(1) for domestic enforcement. Notification No. S.O. 693(E) reduced the Article 11(2) interest tax rate to 10 per cent for beneficial owners but did not incorporate the nil-rate exemptions available under the India-USA or India-Italy DTAAs. Interest on income-tax refunds under section 244A therefore remained taxable at the notified treaty rate, and the nil-rate claim was rejected. Eligible tax deducted at source credit remained available against the refund-interest income.
MFN-based treaty benefits under the India-Netherlands DTAA require a notification under section 90(1) for domestic enforcement. Notification No. S.O. 693(E) reduced the Article 11(2) interest tax rate to 10 per cent for beneficial owners but did not incorporate the nil-rate exemptions available under the India-USA or India-Italy DTAAs. Interest on income-tax refunds under section 244A therefore remained taxable at the notified treaty rate, and the nil-rate claim was rejected. Eligible tax deducted at source credit remained available against the refund-interest income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
