Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e 40% of the revenue generated from sale of distance learning material, attributed to them in their status as that of DAPE of the assessee corporation, viz. IATA, Canada, and assessed as the business income of the assessee in India under Article 7 of the India-Canada tax treaty cannot be sustained and is therefore vacated. - AT
Income deemed to accrue or arise in India - income attributable to India - As we have held that the ATC’s are not the DAPE of the assessee, therefore, the addition i.e 40% of the revenue generated from sale of distance learning material, attributed to them in their status as that of DAPE of the assessee corporation, viz. IATA, Canada, and assessed as the business income of the assessee in India under Article 7 of the India-Canada tax treaty cannot be sustained and is therefore vacated. - AT
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