Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the assessee company nor having any authority to conclude contracts, it has neither concluded any contracts nor has it secured any orders for the assessee company in India, thus, cannot be regarded as agency PE - not taxable in India
Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the assessee company nor having any authority to conclude contracts, it has neither concluded any contracts nor has it secured any orders for the assessee company in India, thus, cannot be regarded as agency PE - not taxable in India
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