Independent manufacturing undertaking eligibility preserves Section 80IA/80IB deductions, while machinery kept ready for use qualifies for depreciatio...
Assessing Officer Satisfaction Requirement Bars Penalty for Cash Receipt in Immovable-Property Sale Cases Where Initiation Lacks Recorded Satisfaction...
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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