Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
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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