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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Section 43A applies only where capital assets are acquired from outside India; foreign-currency denomination or an overseas ECB source does not satisfy that condition for assets acquired in India. Unrealised foreign-exchange gains or losses on year-end reinstatement of ECB liabilities used for indigenous capital assets therefore fall outside section 43A. Section 43AA governs such foreign-exchange fluctuations and requires recognition in accordance with applicable statutory and accounting requirements, without treating the capital or revenue character of the underlying transaction as determinative. The resulting exchange gain must be given effect in computing taxable income.
Section 43A applies only where capital assets are acquired from outside India; foreign-currency denomination or an overseas ECB source does not satisfy that condition for assets acquired in India. Unrealised foreign-exchange gains or losses on year-end reinstatement of ECB liabilities used for indigenous capital assets therefore fall outside section 43A. Section 43AA governs such foreign-exchange fluctuations and requires recognition in accordance with applicable statutory and accounting requirements, without treating the capital or revenue character of the underlying transaction as determinative. The resulting exchange gain must be given effect in computing taxable income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
