Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Page of 4897
Press 'Enter' after typing page number.
561 to 580 of 97923 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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 4897 
