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Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Addition u/s 68, u/s 69A and section 69 - In the explanatory memorandum to Notification No. 103/2019, it is certified that no person is being adversely affected by giving retrospective effect to this notification. - In the present case, assessee has duly discharged its tax liability under the IDS, 2016 which is prior to the extended due date as well as before the notification itself and, therefore, there is no occasion to put him in an adverse situation. - AT
Addition u/s 68, u/s 69A and section 69 - In the explanatory memorandum to Notification No. 103/2019, it is certified that no person is being adversely affected by giving retrospective effect to this notification. - In the present case, assessee has duly discharged its tax liability under the IDS, 2016 which is prior to the extended due date as well as before the notification itself and, therefore, there is no occasion to put him in an adverse situation. - AT
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