Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
Income accrued in India - Non-Resident - taxability of interest on Income Tax Refund - Contrary decisions of different High courts - As in case of ACIT Vs. Clough Engineering Ltd. [2011 (5) TMI 562 - ITAT, DELHI] a view favourable to the assessee has been taken. However, in case of B.J. Services Co. Middle East Ltd. [2015 (5) TMI 1036 - UTTARAKHAND HIGH COURT] the Hon’ble HC, while examining pari materia provision contained in Article 12(6) of India-UK Treaty has held that interest on income tax refund is taxable as business profits under Article 7 of the treaty. In our humble opinion, the decision of the Hon’ble Uttarakhand High Court will carry greater precedentiary value. - AT
Income accrued in India - Non-Resident - taxability of interest on Income Tax Refund - Contrary decisions of different High courts - As in case of ACIT Vs. Clough Engineering Ltd. [2011 (5) TMI 562 - ITAT, DELHI] a view favourable to the assessee has been taken. However, in case of B.J. Services Co. Middle East Ltd. [2015 (5) TMI 1036 - UTTARAKHAND HIGH COURT] the Hon’ble HC, while examining pari materia provision contained in Article 12(6) of India-UK Treaty has held that interest on income tax refund is taxable as business profits under Article 7 of the treaty. In our humble opinion, the decision of the Hon’ble Uttarakhand High Court will carry greater precedentiary value. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
