Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Income deemed to accrue or arise in India - addition on account of LTCG to be taxed u/s 112 - Scope of holding Tax Residency Certificate of Mauritius (TRC) - The Tribunal allowed the appeal, holding that investments made prior to April 1, 2017, are grandfathered under the India-Mauritius DTAA and not subject to capital gains taxation in India. The Tribunal followed the principles laid out in the case of Bid Services Division (Mauritius) Ltd. vs. Authority for Advance Rulings and other relevant CBDT circulars and press releases, confirming that the assessee is entitled to the DTAA benefits.
Income deemed to accrue or arise in India - addition on account of LTCG to be taxed u/s 112 - Scope of holding Tax Residency Certificate of Mauritius (TRC) - The Tribunal allowed the appeal, holding that investments made prior to April 1, 2017, are grandfathered under the India-Mauritius DTAA and not subject to capital gains taxation in India. The Tribunal followed the principles laid out in the case of Bid Services Division (Mauritius) Ltd. vs. Authority for Advance Rulings and other relevant CBDT circulars and press releases, confirming that the assessee is entitled to the DTAA benefits.
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