Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Exemption u/s 10(23C) (vi) - rejection of the application u/s 12AA - allegation of paying interest on unsecured loan to specified persons at higher rate - Whether paying the interest at the rate of 9%/12% to the above then person was a benefit to the specified person, was required to be examined by the AO during the assessment proceedings and for that purposes it was incumbent upon the AO to bring on record the contemporaneous comparative instances of the similar society indicating that the interest of rate paid by the assessee was far more than that was prevailing in the open market. In the light of the above, the first objection raised by the CIT(E) was without any basis. - AT
Exemption u/s 10(23C) (vi) - rejection of the application u/s 12AA - allegation of paying interest on unsecured loan to specified persons at higher rate - Whether paying the interest at the rate of 9%/12% to the above then person was a benefit to the specified person, was required to be examined by the AO during the assessment proceedings and for that purposes it was incumbent upon the AO to bring on record the contemporaneous comparative instances of the similar society indicating that the interest of rate paid by the assessee was far more than that was prevailing in the open market. In the light of the above, the first objection raised by the CIT(E) was without any basis. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
