Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Income accrued in India - Rendering services to non-resident entities - Though, the assessing officer has generally observed that in course of providing services to the assessee, the non-resident entities have made available technical knowledge, know-how, processes to the assessee. However, no substantive material has been brought on record by him to back such conclusion. - it is very much clear, the conditions of Article 12(4) of the tax treaty are not fulfilled. - AT
Income accrued in India - Rendering services to non-resident entities - Though, the assessing officer has generally observed that in course of providing services to the assessee, the non-resident entities have made available technical knowledge, know-how, processes to the assessee. However, no substantive material has been brought on record by him to back such conclusion. - it is very much clear, the conditions of Article 12(4) of the tax treaty are not fulfilled. - AT
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TaxTMI 
TaxTMI 
