Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Income deemed to accrue or arise in India - “Live” Feed or “modified” Feed - Allocation/apportionment of the Licensee Fee income - receipts from Set Setellite Singapore Pte. Ltd. (SET) - benefit of India Singapore Tax Treaty - 25% of Licensee Fee is fair estimation of the Licensee Fee attributable to the Non-Live Exhibitions and recorded content in “Live” Feed. There is no material placed on record by both the sides to arrive at the more precise or better estimation/apportionment. - AT
Income deemed to accrue or arise in India - “Live” Feed or “modified” Feed - Allocation/apportionment of the Licensee Fee income - receipts from Set Setellite Singapore Pte. Ltd. (SET) - benefit of India Singapore Tax Treaty - 25% of Licensee Fee is fair estimation of the Licensee Fee attributable to the Non-Live Exhibitions and recorded content in “Live” Feed. There is no material placed on record by both the sides to arrive at the more precise or better estimation/apportionment. - AT
Note: It is a system-generated summary and is for quick reference only.