Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against offered to tax as interest income under Article 12 of India-France DTAA ? - The Tribunal held that the interest on income tax refund is to be taxed at the rate of 10% under Article 12 of the India-France DTAA, as it was not effectively connected with the Permanent Establishment in India.
Taxability of interest on income tax refund received - PE in India or not? - whether shall be taxable as business income under Article 7 of India-France DTAA as against offered to tax as interest income under Article 12 of India-France DTAA ? - The Tribunal held that the interest on income tax refund is to be taxed at the rate of 10% under Article 12 of the India-France DTAA, as it was not effectively connected with the Permanent Establishment in India.
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