Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Tax residency certificate and Global Business License-I held by assessee investment fund incorporated in Mauritius as subsidiary of another Mauritian company. Investments made in Indian companies for over five years before transfer earning long-term capital gains. No evidence of fund flow from India. Conduit status alleged based on immediate transfer of funds after divestment, but commercial rationale established as business model to attract foreign investment. Suspicion alone insufficient to rebut statutory presumption of genuineness based on tax residency certificate. Treaty benefits rightly allowed.
Tax residency certificate and Global Business License-I held by assessee investment fund incorporated in Mauritius as subsidiary of another Mauritian company. Investments made in Indian companies for over five years before transfer earning long-term capital gains. No evidence of fund flow from India. Conduit status alleged based on immediate transfer of funds after divestment, but commercial rationale established as business model to attract foreign investment. Suspicion alone insufficient to rebut statutory presumption of genuineness based on tax residency certificate. Treaty benefits rightly allowed.
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TaxTMI 
TaxTMI 
