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...
Taxability of income in India - Interest income on income tax refund - As referring to relevant Article 11 of Indo-US DTAA with regard to interest it can be concluded that interest on income tax refund is not effectively connected with the PE either on the basis of asset- test or activity- test. Hence, it is taxable as per the provisions in the Para No. 2 of Article XI of Indo- US DTAA. - AT
Taxability of income in India - Interest income on income tax refund - As referring to relevant Article 11 of Indo-US DTAA with regard to interest it can be concluded that interest on income tax refund is not effectively connected with the PE either on the basis of asset- test or activity- test. Hence, it is taxable as per the provisions in the Para No. 2 of Article XI of Indo- US DTAA. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
