Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
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The Appellate Tribunal upheld the validity of the National Faceless Assessment Centre's notice u/s 143(2) for the assessee. Regarding tax rates for domestic companies and cooperative banks u/s 90, the Tribunal referred to past decisions and dismissed the appeal. Data processing fees paid by the Indian branch to the Singapore branch were deemed non-taxable. Interest payments by Indian branches to the head office were analyzed u/s 12 and 7 of the India-France DTAA, concluding that interest income of the head office is not taxable under the DTAA. An addition under profit and gain from business was remanded for further assessment. The Tribunal's decisions were based on legal interpretations and past precedents, leading to the dismissal or allowance of various grounds of appeal.
The Appellate Tribunal upheld the validity of the National Faceless Assessment Centre's notice u/s 143(2) for the assessee. Regarding tax rates for domestic companies and cooperative banks u/s 90, the Tribunal referred to past decisions and dismissed the appeal. Data processing fees paid by the Indian branch to the Singapore branch were deemed non-taxable. Interest payments by Indian branches to the head office were analyzed u/s 12 and 7 of the India-France DTAA, concluding that interest income of the head office is not taxable under the DTAA. An addition under profit and gain from business was remanded for further assessment. The Tribunal's decisions were based on legal interpretations and past precedents, leading to the dismissal or allowance of various grounds of appeal.
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