Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
Scientific research association approval requires continuing SIRO status, annual donation reporting, and donor certificates for the approved foundatio...
Scientific research institution approval is conditional on SIRO recognition, annual donation reporting, donor certification, and prescribed compliance...
The Appellate Tribunal addressed various issues: 1. Validity of assessment - Notice u/s 143(2) properly issued. 2. Tax rate for domestic companies - Non-discrimination clause of India-France Tax Treaty upheld. 3. Taxability of data processing fees - Charges to overseas branch not taxable. 4. Taxability of interest paid by branch office - Interest not taxable under DTAA if connected to Permanent Establishment in India. Tribunal ruled in favor of the assessee on all counts, rejecting Revenue's claims.
The Appellate Tribunal addressed various issues: 1. Validity of assessment - Notice u/s 143(2) properly issued. 2. Tax rate for domestic companies - Non-discrimination clause of India-France Tax Treaty upheld. 3. Taxability of data processing fees - Charges to overseas branch not taxable. 4. Taxability of interest paid by branch office - Interest not taxable under DTAA if connected to Permanent Establishment in India. Tribunal ruled in favor of the assessee on all counts, rejecting Revenue's claims.
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