Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
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Income deemed to accrue or arise in India - revenue earned by the assessee from the provisions of transmission services of voice, data and programmes of space segment capacity on Satellites to customers - AO held it in the nature of “Royalty” u/s 9(1)(vi) of the Income Tax Act and Article 12(4) of the India-Netherland DTAA - The ITAT, while deleting the additions, held that, it is fallacious to assume that any change made to domestic law to rectify a situation of mistaken interpretation can spontaneously further their case in an international treaty. Therefore, mere amendment to Section 9(1)(vi) cannot result in a change.
Income deemed to accrue or arise in India - revenue earned by the assessee from the provisions of transmission services of voice, data and programmes of space segment capacity on Satellites to customers - AO held it in the nature of “Royalty” u/s 9(1)(vi) of the Income Tax Act and Article 12(4) of the India-Netherland DTAA - The ITAT, while deleting the additions, held that, it is fallacious to assume that any change made to domestic law to rectify a situation of mistaken interpretation can spontaneously further their case in an international treaty. Therefore, mere amendment to Section 9(1)(vi) cannot result in a change.
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