Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Appellant booked artificial short-term capital loss by purchasing shares from group entities at exorbitant rates and selling same shares to other group entities at lower rates to offset huge capital gains. Transaction lacked genuineness, designed solely to avoid taxes. Cost of purchase rightly recomputed by authorities at Rs.33 per share. Interest expenditure disallowed u/s 14A as appellant failed to substantiate investments were for strategic business purposes, admitted using interest-bearing funds for non-business investments yielding exempt income. CIT(A)'s order upheld, assessee's appeal dismissed by Appellate Tribunal.
Appellant booked artificial short-term capital loss by purchasing shares from group entities at exorbitant rates and selling same shares to other group entities at lower rates to offset huge capital gains. Transaction lacked genuineness, designed solely to avoid taxes. Cost of purchase rightly recomputed by authorities at Rs.33 per share. Interest expenditure disallowed u/s 14A as appellant failed to substantiate investments were for strategic business purposes, admitted using interest-bearing funds for non-business investments yielding exempt income. CIT(A)'s order upheld, assessee's appeal dismissed by Appellate Tribunal.
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TaxTMI 
TaxTMI 
of 4886 
