Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
TDS u/s 195 - There should be a “debt claim and ‘form’ such claim income should arise to qualify as ‘interest’. Thus the word ‘debt claim “predicate the existence of debtor – creditor relationship [lender – borrower]. That relationship can arise only when there is a provision of capital. - Guarantee fee paid by the assessee to Netherlands company cannot be covered in the definition of interest as per Article 11 of The DTAA..
TDS u/s 195 - There should be a “debt claim and ‘form’ such claim income should arise to qualify as ‘interest’. Thus the word ‘debt claim “predicate the existence of debtor – creditor relationship [lender – borrower]. That relationship can arise only when there is a provision of capital. - Guarantee fee paid by the assessee to Netherlands company cannot be covered in the definition of interest as per Article 11 of The DTAA..
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