Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
Interest arising from State Government funds advanced to an assessee is not taxable in the assessee's hands where the interest belongs to the State Government, including where the same issue has been determined for an earlier assessment year. Conversely, a signature bonus received on transferring developed power projects constitutes a revenue receipt when developing and transferring such projects forms part of the taxpayer's ordinary business and involves expenditure on surveys, testing and approvals. The distinction turns on beneficial ownership of the interest and the receipt's direct connection with regular business operations.
Interest arising from State Government funds advanced to an assessee is not taxable in the assessee's hands where the interest belongs to the State Government, including where the same issue has been determined for an earlier assessment year. Conversely, a signature bonus received on transferring developed power projects constitutes a revenue receipt when developing and transferring such projects forms part of the taxpayer's ordinary business and involves expenditure on surveys, testing and approvals. The distinction turns on beneficial ownership of the interest and the receipt's direct connection with regular business operations.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
