Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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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