Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Characterization of arbitral award compensation as business income under India-Japan tax treaty. Principal portion arising from contractual obligation constitutes business income, not taxable in India due to absence of permanent establishment. Interest on compensation partakes character of business receipts, not separable as income from other sources. Entire compensation construed as business income, not taxable in India under Article 7 of tax treaty. Double addition of interest income offered in return to be deleted by Assessing Officer. Penalty proceedings unsustainable due to deletion of additions. Appellate Tribunal's decision on taxability, double deduction, and penalty.
Characterization of arbitral award compensation as business income under India-Japan tax treaty. Principal portion arising from contractual obligation constitutes business income, not taxable in India due to absence of permanent establishment. Interest on compensation partakes character of business receipts, not separable as income from other sources. Entire compensation construed as business income, not taxable in India under Article 7 of tax treaty. Double addition of interest income offered in return to be deleted by Assessing Officer. Penalty proceedings unsustainable due to deletion of additions. Appellate Tribunal's decision on taxability, double deduction, and penalty.
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