Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Taxability of non-resident receipts depends on a real and substantive nexus between India and the income-producing right or activity, or on a specific statutory deeming provision; an Indian payer's residence, accounting treatment, expenditure claim or remittance alone is insufficient. Overseas contractual rights, settlement and market exploitation do not create Indian accrual merely through foreign anti-trust allegations unsupported by a judicial finding or admission. Advance-ruling jurisdiction is confined to the applicant and transaction, and prima facie tax avoidance requires an identified Indian tax incidence. Extended reassessment limitation requires a qualifying asset belonging to the assessee and prior meaningful opportunity on that ground. Protective assessment may address uncertainty over the taxable person but cannot support protective recovery; TDS refunds may be secured pending substantive assessment.
Taxability of non-resident receipts depends on a real and substantive nexus between India and the income-producing right or activity, or on a specific statutory deeming provision; an Indian payer's residence, accounting treatment, expenditure claim or remittance alone is insufficient. Overseas contractual rights, settlement and market exploitation do not create Indian accrual merely through foreign anti-trust allegations unsupported by a judicial finding or admission. Advance-ruling jurisdiction is confined to the applicant and transaction, and prima facie tax avoidance requires an identified Indian tax incidence. Extended reassessment limitation requires a qualifying asset belonging to the assessee and prior meaningful opportunity on that ground. Protective assessment may address uncertainty over the taxable person but cannot support protective recovery; TDS refunds may be secured pending substantive assessment.
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