Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Income deemed to accrue or arise in India - TSIS Service Fee received - The term ‘Royalty’ is not as widely defined in India France DTAA as in the India Singapore DTAA, which was taken into consideration by the coordinate bench of the Tribunal in the case of sister concern. - AO directed to delete the addition in respect of TSIS Service Fees received by the assessee. - AT
Income deemed to accrue or arise in India - TSIS Service Fee received - The term ‘Royalty’ is not as widely defined in India France DTAA as in the India Singapore DTAA, which was taken into consideration by the coordinate bench of the Tribunal in the case of sister concern. - AO directed to delete the addition in respect of TSIS Service Fees received by the assessee. - AT
Note: It is a system-generated summary and is for quick reference only.