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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Determination of tax liability and treatment as Association of Persons (AOP) for assessee trusts. Examination required on whether income taxable at slab rates u/s 164(1) or as AOP u/s 167B at Maximum Marginal Rate. Rectification application pending u/s 154. Issue restored to Assessing Officer for fresh consideration after examining all relevant details and documents. Appeals allowed for statistical purposes. Jurisdictional Assessing Officer to examine and verify necessary details for determining appropriate tax treatment.
Determination of tax liability and treatment as Association of Persons (AOP) for assessee trusts. Examination required on whether income taxable at slab rates u/s 164(1) or as AOP u/s 167B at Maximum Marginal Rate. Rectification application pending u/s 154. Issue restored to Assessing Officer for fresh consideration after examining all relevant details and documents. Appeals allowed for statistical purposes. Jurisdictional Assessing Officer to examine and verify necessary details for determining appropriate tax treatment.
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