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...
Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments presented by both parties and examined relevant provisions of the Income Tax Act and the India-Mauritius tax treaty. It noted that the assessee, being a foreign company, did not have a permanent establishment (PE) in India. Additionally, there was no specific clause in the tax treaty addressing the taxability of the income in question. - ITAT held that in the absence of a permanent establishment and specific treaty provisions, the income should be treated as business profits and is not taxable in India.
Income taxable in India or not - Taxation of Technical Collaboration Fees @ 10% u/s. 9(1)(vii) r.w.s 115A(1)(b) - The Appellate Tribunal considered the arguments presented by both parties and examined relevant provisions of the Income Tax Act and the India-Mauritius tax treaty. It noted that the assessee, being a foreign company, did not have a permanent establishment (PE) in India. Additionally, there was no specific clause in the tax treaty addressing the taxability of the income in question. - ITAT held that in the absence of a permanent establishment and specific treaty provisions, the income should be treated as business profits and is not taxable in India.
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