Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Non-resident individual seconded on overseas assignment to UK - Salary received for employment exercised in UK taxable only in UK under Article 15(1) of India-UK DTAA, not taxable in India. Proportionate salary for services rendered in India offered to tax in India, balance salary offered to tax in UK, no foreign tax credit claimed. Identical issue decided in favor of assessee in Nanthakumar Murugesan case. Appellate Tribunal upheld deleting the addition made by lower authorities, deciding in favor of assessee on taxability of salary earned during overseas assignment.
Non-resident individual seconded on overseas assignment to UK - Salary received for employment exercised in UK taxable only in UK under Article 15(1) of India-UK DTAA, not taxable in India. Proportionate salary for services rendered in India offered to tax in India, balance salary offered to tax in UK, no foreign tax credit claimed. Identical issue decided in favor of assessee in Nanthakumar Murugesan case. Appellate Tribunal upheld deleting the addition made by lower authorities, deciding in favor of assessee on taxability of salary earned during overseas assignment.
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