Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Benefit of DTAA against Dividend Distribution Tax (DDT) - whether the benefit of DTAA can be extended to domestic company? - The Protocol with reference to Article 10 as per India Hungary DTAA on taxability of distributed profits cannot be interpreted so as to say that it covers the domestic companies, since there is no specific clause in the Treaty to that effect. Consequently assessee's claim of refund of DDT in respect of shareholders covered under India Netherlands DTAA is rejected. - AT
Benefit of DTAA against Dividend Distribution Tax (DDT) - whether the benefit of DTAA can be extended to domestic company? - The Protocol with reference to Article 10 as per India Hungary DTAA on taxability of distributed profits cannot be interpreted so as to say that it covers the domestic companies, since there is no specific clause in the Treaty to that effect. Consequently assessee's claim of refund of DDT in respect of shareholders covered under India Netherlands DTAA is rejected. - AT
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TaxTMI 
TaxTMI 
of 4886 
