Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
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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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