Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Disallowance u/s.40(a)(i) - India USA DTAA - based on proceedings u/s.201(1)/(1A) for default in non-deduction of TDS - once in appellate order in respect of proceedings u/s.201(1)/(1A) has held that the assessee is not liable for deduction of tax at source, the sequitur is that there cannot be any disallowance u/s.40(a)(i) as the same can be made
Disallowance u/s.40(a)(i) - India USA DTAA - based on proceedings u/s.201(1)/(1A) for default in non-deduction of TDS - once in appellate order in respect of proceedings u/s.201(1)/(1A) has held that the assessee is not liable for deduction of tax at source, the sequitur is that there cannot be any disallowance u/s.40(a)(i) as the same can be made
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