Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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