Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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Taxability of income in India - deduction with respect to salaries paid by appellant in foreign currency outside India to expatriates working in India - Indo-Japan tax treaty. Following Emirates Commercial Bank Ltd. and Supreme Court's view in Goetze (India) Ltd., exception carved out for statutory prohibition of deduction claimed outside Return of Income not applicable in case of Tribunal or Court direction. HC quashed order denying relief to petitioner regarding deductions liable pursuant to Tribunal order.
Taxability of income in India - deduction with respect to salaries paid by appellant in foreign currency outside India to expatriates working in India - Indo-Japan tax treaty. Following Emirates Commercial Bank Ltd. and Supreme Court's view in Goetze (India) Ltd., exception carved out for statutory prohibition of deduction claimed outside Return of Income not applicable in case of Tribunal or Court direction. HC quashed order denying relief to petitioner regarding deductions liable pursuant to Tribunal order.
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