Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
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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