Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Income deemed to accrue or arise in India - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees for Technical Services (FTS) under domestic law or India-Austria tax treaty. Offshore supply closely linked to offshore supply of plant and equipment, cannot be segregated as basic nature and character identical. Onshore supervisory services taxable as business profits under tax treaty, not as FTS on gross basis. Receipts connected to Permanent Establishment (PE), to be taxed on net basis under Article 7. Certain other supervisory fees taxable as FTS under Article 12(4) of tax treaty, irrespective of PE. Reimbursement of expenses from Indian group companies for group information and business services not taxable as FTS, being cost sharing without profit element.
Income deemed to accrue or arise in India - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees for Technical Services (FTS) under domestic law or India-Austria tax treaty. Offshore supply closely linked to offshore supply of plant and equipment, cannot be segregated as basic nature and character identical. Onshore supervisory services taxable as business profits under tax treaty, not as FTS on gross basis. Receipts connected to Permanent Establishment (PE), to be taxed on net basis under Article 7. Certain other supervisory fees taxable as FTS under Article 12(4) of tax treaty, irrespective of PE. Reimbursement of expenses from Indian group companies for group information and business services not taxable as FTS, being cost sharing without profit element.
Note: It is a system-generated summary and is for quick reference only.
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