Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Denial of treaty benefits treating the assessee as a conduit company set up - Taxability of long-term capital gain claimed as exempt under Article 13(4) of India – Mauritius DTAA - Though, AO has alleged that the assessee is a conduit company and has been set up as a part of tax avoidance arrangement, surprisingly, he has not invoked the provisions of GAAR as provided under Chapter XA of the Act. - TRC issued by the competent authority in Mauritius has to be accepted - AT
Denial of treaty benefits treating the assessee as a conduit company set up - Taxability of long-term capital gain claimed as exempt under Article 13(4) of India – Mauritius DTAA - Though, AO has alleged that the assessee is a conduit company and has been set up as a part of tax avoidance arrangement, surprisingly, he has not invoked the provisions of GAAR as provided under Chapter XA of the Act. - TRC issued by the competent authority in Mauritius has to be accepted - AT
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