Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to the vessel providing companies (VPCs) under global usage under bareboat charter (BBC) agreements is deemed to accrue and arise in India and is liable to tax in India under the Income-tax Act and, therefore, subject to withholding tax in India. - The income liable to tax is to be assessed as business income under the provisions of section 44BB of the Act. - AAR
Income accrued in India - permanent establishment (PE) - Withholding of tax in India - vessel engaged in seismic survey at high sea - The sum paid by the applicant to the vessel providing companies (VPCs) under global usage under bareboat charter (BBC) agreements is deemed to accrue and arise in India and is liable to tax in India under the Income-tax Act and, therefore, subject to withholding tax in India. - The income liable to tax is to be assessed as business income under the provisions of section 44BB of the Act. - AAR
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