Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
TDS u/s 195 - Disallowance u/s.40(a)(i) - As the case is admittedly covered u/s.9(1)(vi) of the Act and also found to be covered by Article 12 of the amended DTAA, we hold that the amount paid by the assessee is chargeable to tax in the hands of the Netherlands entity. Failure of the assessee to deduct tax at source from payment made to the Netherlands entity clearly magnetizes section 40(a)(i) of the Act. - AT
TDS u/s 195 - Disallowance u/s.40(a)(i) - As the case is admittedly covered u/s.9(1)(vi) of the Act and also found to be covered by Article 12 of the amended DTAA, we hold that the amount paid by the assessee is chargeable to tax in the hands of the Netherlands entity. Failure of the assessee to deduct tax at source from payment made to the Netherlands entity clearly magnetizes section 40(a)(i) of the Act. - AT
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