Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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Compensation received on termination of network participation agreement from Citibank - Income deemed to accrue or arise in India - received does not fit into any of the definition of royalty either under IT Act or as per DTAA - it falls u/s.28(va)(b) as the business receipt and As per Article 7 of Indo-US DTAA, same is taxable only in USA and not in India - matter however, remanded to inquire for existence of PE in India
Compensation received on termination of network participation agreement from Citibank - Income deemed to accrue or arise in India - received does not fit into any of the definition of royalty either under IT Act or as per DTAA - it falls u/s.28(va)(b) as the business receipt and As per Article 7 of Indo-US DTAA, same is taxable only in USA and not in India - matter however, remanded to inquire for existence of PE in India
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