Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
The Appellate Tribunal considered the taxability of freight income u/s 44B for a foreign company incorporated in Singapore operating ships globally, including in India. The company argued that under Article 8 of the India-Singapore Treaty, shipping income should only be taxed in Singapore, its resident state. The Tribunal held that income from shipping in international traffic is taxable only in the resident state as per the treaty. The Tribunal rejected the application of Article 24 of the Treaty, as the company demonstrated its income was taxed in Singapore on accrual basis. Citing precedent, the Tribunal ruled in favor of the company, directing the deletion of additions to its Indian shipping income. The Appeals of the assesses were allowed.
The Appellate Tribunal considered the taxability of freight income u/s 44B for a foreign company incorporated in Singapore operating ships globally, including in India. The company argued that under Article 8 of the India-Singapore Treaty, shipping income should only be taxed in Singapore, its resident state. The Tribunal held that income from shipping in international traffic is taxable only in the resident state as per the treaty. The Tribunal rejected the application of Article 24 of the Treaty, as the company demonstrated its income was taxed in Singapore on accrual basis. Citing precedent, the Tribunal ruled in favor of the company, directing the deletion of additions to its Indian shipping income. The Appeals of the assesses were allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
