Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Income deemed to accrue or arise in India - Payments received by the assessee from it Indian customers on account of Centralized Services - Fee for Technical Services as defined u/s 9(1)(vii) of the Income Tax Act, 1961 or “Fee for included Services as defined u/Article 12(4)(a) of the India-US DTAA - The Appellate Tribunal, after considering the submissions and precedents, upheld the decision of the CIT(A), agreeing that the payments received by the assessee were not in the nature of FTS under the Income Tax Act or the DTAA. The Tribunal noted that the issue was squarely covered in favor of the assessee by its own past cases and the rulings of the Hon'ble Delhi High Court.
Income deemed to accrue or arise in India - Payments received by the assessee from it Indian customers on account of Centralized Services - Fee for Technical Services as defined u/s 9(1)(vii) of the Income Tax Act, 1961 or “Fee for included Services as defined u/Article 12(4)(a) of the India-US DTAA - The Appellate Tribunal, after considering the submissions and precedents, upheld the decision of the CIT(A), agreeing that the payments received by the assessee were not in the nature of FTS under the Income Tax Act or the DTAA. The Tribunal noted that the issue was squarely covered in favor of the assessee by its own past cases and the rulings of the Hon'ble Delhi High Court.
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