Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy the “make available” clause as per article 12(4)(b) of Indo Singapore DTAA and, therefore, the amounts are attributable for these services cannot be held to be fees for technical services. - AT
Income accrued in India - Fee for Technical Services [FTS] - 'make available’ - the marketing and sales services, operations and standardization services do not satisfy the “make available” clause as per article 12(4)(b) of Indo Singapore DTAA and, therefore, the amounts are attributable for these services cannot be held to be fees for technical services. - AT
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