Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
Income deemed to accrue or arise in India - Since there article 8 of the Indo Bhutan DTAA is more beneficial to the assessee, therefore the profits derived by the assessee from the operation of ships or aircraft in international traffic are liable to be taxed in the contracting state in which its place of effective management of the enterprise is situated, which undisputedly is Bhutan. - AT
Income deemed to accrue or arise in India - Since there article 8 of the Indo Bhutan DTAA is more beneficial to the assessee, therefore the profits derived by the assessee from the operation of ships or aircraft in international traffic are liable to be taxed in the contracting state in which its place of effective management of the enterprise is situated, which undisputedly is Bhutan. - AT
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