Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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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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