International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Income accrued in India - Having considered the facts in totality and discussed in preceding paras, we do not see any commercial or economic rationale or ease of doing business in incorporating the applicant in Mauritius and interposing it in the JV. - the applicant is not entitled to benefit under Article 13(4) of Indo-Mauritius DTAA in regard to gains arising from the transaction of sale of shares. - AAR
Income accrued in India - Having considered the facts in totality and discussed in preceding paras, we do not see any commercial or economic rationale or ease of doing business in incorporating the applicant in Mauritius and interposing it in the JV. - the applicant is not entitled to benefit under Article 13(4) of Indo-Mauritius DTAA in regard to gains arising from the transaction of sale of shares. - AAR
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