Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Entitlement to benefits of treaty exemption - India-Singapore DTAA - Application of Section 172 - Taxation of shipping companies - The tribunal concluded that the arguments regarding the denial of tax treaty benefits and the condition of remittance required a re-evaluation of the evidence, particularly the letter from IRAS. Given the discrepancies and the need for further clarification, the tribunal remanded the matter to the Assessing Officer for detailed verification of the IRAS certificate and its implications on the assessee's tax liability under the India-Singapore DTAA.
Entitlement to benefits of treaty exemption - India-Singapore DTAA - Application of Section 172 - Taxation of shipping companies - The tribunal concluded that the arguments regarding the denial of tax treaty benefits and the condition of remittance required a re-evaluation of the evidence, particularly the letter from IRAS. Given the discrepancies and the need for further clarification, the tribunal remanded the matter to the Assessing Officer for detailed verification of the IRAS certificate and its implications on the assessee's tax liability under the India-Singapore DTAA.
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