Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Taxability of capital gain arising on sale of shares under the treaty provisions - AO and DRP have rejected assessee’s claim by holding that assessee being a mere paper company is not entitled to treaty benefits - vague allegations - The tribunal found that the denial of treaty benefits to the assessee was based on vague allegations without substantial evidence and allowed the exemption under Article 13(4) of the tax treaty. - The tribunal allowed the exemption under Article 13(4) of the tax treaty qua the capital gain arising on sale of shares.
Taxability of capital gain arising on sale of shares under the treaty provisions - AO and DRP have rejected assessee’s claim by holding that assessee being a mere paper company is not entitled to treaty benefits - vague allegations - The tribunal found that the denial of treaty benefits to the assessee was based on vague allegations without substantial evidence and allowed the exemption under Article 13(4) of the tax treaty. - The tribunal allowed the exemption under Article 13(4) of the tax treaty qua the capital gain arising on sale of shares.
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