Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Taxability of reimbursement of expenses as FTS - the recipients are receiving such services on a continuous basis from year to year, which shows that the recipients are not capable of independently performing such services without the aid and assistance of the assessee. - the reimbursement of cost received by the assessee, cannot be treated as FTS under Article 12(4) of the India-Singapore DTAA, at least, based on the facts involved in the impugned assessment years. - AT
Taxability of reimbursement of expenses as FTS - the recipients are receiving such services on a continuous basis from year to year, which shows that the recipients are not capable of independently performing such services without the aid and assistance of the assessee. - the reimbursement of cost received by the assessee, cannot be treated as FTS under Article 12(4) of the India-Singapore DTAA, at least, based on the facts involved in the impugned assessment years. - AT
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