Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Accrual of income in India - existence of DAPE - PE in India or not? - The ITAT previously ruled in favor of the Assessee regarding the existence of a fixed place PE. However, the DRP's directions in the present assessment were based on a misunderstanding of the previous decisions. - The Tribunal sets aside the assessment order and directs the DRP to re-examine the issue of the existence of DAPE, providing an opportunity for the Assessee to be heard.
Accrual of income in India - existence of DAPE - PE in India or not? - The ITAT previously ruled in favor of the Assessee regarding the existence of a fixed place PE. However, the DRP's directions in the present assessment were based on a misunderstanding of the previous decisions. - The Tribunal sets aside the assessment order and directs the DRP to re-examine the issue of the existence of DAPE, providing an opportunity for the Assessee to be heard.
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