Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Assessee, registered in Mauritius with tax residency certificate, claimed long-term capital gains from sale of shares as exempt under Article 13(4) of India-Mauritius DTAA. LEI Singapore Holdings deducted withholding tax on payments made to assessee, who sought refund. Coordinate Bench, relying on decisions in Bid Services Division and Vodafone International Holding, held that assessee's long-term capital gain on share sale is not taxable in India, deciding in assessee's favor for refund of TDS deducted.
Assessee, registered in Mauritius with tax residency certificate, claimed long-term capital gains from sale of shares as exempt under Article 13(4) of India-Mauritius DTAA. LEI Singapore Holdings deducted withholding tax on payments made to assessee, who sought refund. Coordinate Bench, relying on decisions in Bid Services Division and Vodafone International Holding, held that assessee's long-term capital gain on share sale is not taxable in India, deciding in assessee's favor for refund of TDS deducted.
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