Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Additions (Benefit) u/s 28(iv) - Expenditure incurred by the HO for salary paid to the expatriate employees for rendering services to PE - The tribunal upheld the allowance of salary expenses paid to expatriate employees, rejecting the revenue's argument under Section 28(iv) of the Income Tax Act that unrecorded expenses should lead to deemed income. The tribunal agreed that since these expenses had already been subjected to tax as salary income in the employees' returns, they did not constitute a benefit under Section 28(iv).
Additions (Benefit) u/s 28(iv) - Expenditure incurred by the HO for salary paid to the expatriate employees for rendering services to PE - The tribunal upheld the allowance of salary expenses paid to expatriate employees, rejecting the revenue's argument under Section 28(iv) of the Income Tax Act that unrecorded expenses should lead to deemed income. The tribunal agreed that since these expenses had already been subjected to tax as salary income in the employees' returns, they did not constitute a benefit under Section 28(iv).
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