Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Exemption u/s 10(26) - Exemption to individual members of Scheduled Tribes - Whether a partnership firm, formed by individual partners who are entitled to an exemption u/s 10(26), can claim the same exemption. - The tribunal observed that under the Income Tax Act, a partnership firm is treated as a separate and distinct entity from its partners. The Act expressly includes firms in the definition of "person" for the purpose of tax assessment, making them separately assessable entities. - The exemption u/s 10(26) of the Income Tax Act, specifically granted to individual members of Scheduled Tribes, cannot be extended to partnership firms, even if they are solely constituted of such individuals.
Exemption u/s 10(26) - Exemption to individual members of Scheduled Tribes - Whether a partnership firm, formed by individual partners who are entitled to an exemption u/s 10(26), can claim the same exemption. - The tribunal observed that under the Income Tax Act, a partnership firm is treated as a separate and distinct entity from its partners. The Act expressly includes firms in the definition of "person" for the purpose of tax assessment, making them separately assessable entities. - The exemption u/s 10(26) of the Income Tax Act, specifically granted to individual members of Scheduled Tribes, cannot be extended to partnership firms, even if they are solely constituted of such individuals.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
