Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in India. Disallowance for payments to non-residents for services rendered outside India like VAT compliance, segregation charges for warehousing and delivery, advertisement expenses was deleted as the services did not constitute technical services and the non-residents had no permanent establishment in India. Expenditure towards corporate social responsibility was held allowable as revenue expenditure for the relevant years. Disallowance of interest on interest-free advances to a foundation was remitted back for verification of availability of interest-free funds. Disallowance u/s 80G was remitted back for verification of the donation certificate. Disallowance for market research expenses paid to a US entity was deleted as it did not constitute fees for technical services under the India-US tax treaty.
TDS disallowance for professional fees paid to non-residents without TDS deduction was deleted as the payees did not have a fixed base or permanent establishment in India. Disallowance for payments to non-residents for services rendered outside India like VAT compliance, segregation charges for warehousing and delivery, advertisement expenses was deleted as the services did not constitute technical services and the non-residents had no permanent establishment in India. Expenditure towards corporate social responsibility was held allowable as revenue expenditure for the relevant years. Disallowance of interest on interest-free advances to a foundation was remitted back for verification of availability of interest-free funds. Disallowance u/s 80G was remitted back for verification of the donation certificate. Disallowance for market research expenses paid to a US entity was deleted as it did not constitute fees for technical services under the India-US tax treaty.
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