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...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
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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