Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
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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