Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Income deemed to accrue or arise in India - The centralised services income, by a reasonable measure, outstrips the royalty income. Thus, rather than centralised service income being ancillary and incidental to royalty income, in reality, it is a reverse situation. In such a scenario, it cannot be said that centralised service income, being ancillary and incidental to royalty income, would fall under Article 12(4)(a) of the Tax Treaty. - Additions deleted - AT
Income deemed to accrue or arise in India - The centralised services income, by a reasonable measure, outstrips the royalty income. Thus, rather than centralised service income being ancillary and incidental to royalty income, in reality, it is a reverse situation. In such a scenario, it cannot be said that centralised service income, being ancillary and incidental to royalty income, would fall under Article 12(4)(a) of the Tax Treaty. - Additions deleted - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
