Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Article 24(2) of the India-Netherlands DTAA does not entitle an Indian permanent establishment of a Netherlands bank to domestic-company tax rates where it remains a foreign company; the section 90 Explanation treats a higher foreign-company rate as non-discriminatory. Article 7's separate-enterprise fiction requires consistent treatment: interest remitted by an Indian PE to its overseas head office or branches is taxable in India, requires withholding, and is disallowed if withholding fails; interest received from them is taxable PE business income. ATMs qualify as computers for depreciation based on functional utility. Accounting Standard 19 does not govern tax characterisation; vehicle hiring payments remain deductible revenue expenditure absent an intention to acquire ownership.
Article 24(2) of the India-Netherlands DTAA does not entitle an Indian permanent establishment of a Netherlands bank to domestic-company tax rates where it remains a foreign company; the section 90 Explanation treats a higher foreign-company rate as non-discriminatory. Article 7's separate-enterprise fiction requires consistent treatment: interest remitted by an Indian PE to its overseas head office or branches is taxable in India, requires withholding, and is disallowed if withholding fails; interest received from them is taxable PE business income. ATMs qualify as computers for depreciation based on functional utility. Accounting Standard 19 does not govern tax characterisation; vehicle hiring payments remain deductible revenue expenditure absent an intention to acquire ownership.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
