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 8 of the India-UK DTAA confines treaty protection to profits from international aircraft operations, qualifying pool participation, and activities directly connected with the enterprise's own transportation. Engineering and ground-handling services supplied to other airlines constitute taxable third-party commercial service income where they lack that direct nexus and do not arise from a qualifying pool. An IATP arrangement requires evidence of its substantive pooling character, including applicable arrangements and reciprocal operations; its label or aviation-related nature is insufficient. Treaty-specific wording controls: provisions in other DTAAs concerning pools, joint businesses or reciprocal facilities cannot expand the India-UK definition, and OECD commentary cannot override an express treaty definition.
Article 8 of the India-UK DTAA confines treaty protection to profits from international aircraft operations, qualifying pool participation, and activities directly connected with the enterprise's own transportation. Engineering and ground-handling services supplied to other airlines constitute taxable third-party commercial service income where they lack that direct nexus and do not arise from a qualifying pool. An IATP arrangement requires evidence of its substantive pooling character, including applicable arrangements and reciprocal operations; its label or aviation-related nature is insufficient. Treaty-specific wording controls: provisions in other DTAAs concerning pools, joint businesses or reciprocal facilities cannot expand the India-UK definition, and OECD commentary cannot override an express treaty definition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
