Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Income deemed to accrue or arise in India - taxation of entire revenue received by the Appellant from provision of legal services on Indian engagements - Fees for Technical Services (FTS) - The tribunal critically analyzed the appellant's claim to the benefits under the India-UK DTAA. The Revenue argued that the appellant, being a fiscally transparent entity in the UK, did not qualify as a 'resident' under the DTAA, and hence, was not eligible for the treaty benefits. The tribunal, however, was persuaded by the appellant’s argument, supported by precedents and the tax treaty's provisions, that the income taxed in the UK in the hands of its UK tax resident partners should entitle the LLP to treaty benefits. - The tribunal allowed the appeal in favor of the appellant, setting aside the orders of the lower authorities regarding the taxability under FTS and the denial of DTAA benefits.
Income deemed to accrue or arise in India - taxation of entire revenue received by the Appellant from provision of legal services on Indian engagements - Fees for Technical Services (FTS) - The tribunal critically analyzed the appellant's claim to the benefits under the India-UK DTAA. The Revenue argued that the appellant, being a fiscally transparent entity in the UK, did not qualify as a 'resident' under the DTAA, and hence, was not eligible for the treaty benefits. The tribunal, however, was persuaded by the appellant’s argument, supported by precedents and the tax treaty's provisions, that the income taxed in the UK in the hands of its UK tax resident partners should entitle the LLP to treaty benefits. - The tribunal allowed the appeal in favor of the appellant, setting aside the orders of the lower authorities regarding the taxability under FTS and the denial of DTAA benefits.
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