Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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The ITAT held that the income received by the assessee from Indian customers for providing a cloud-native machine data analytics solution did not qualify as "Fees for Technical Services" (FTS) under the Income Tax Act, 1961 and the India-US DTAA. The assessee had submitted a Tax Residency Certificate (TRC) and offered the income generated in India as business income in the resident country, as required by law. Consequently, the grounds of appeal nos. 1 to 6 filed by the assessee were allowed. Regarding TDS credit, the ITAT directed the Assessing Officer to verify and allow the same as per law.
The ITAT held that the income received by the assessee from Indian customers for providing a cloud-native machine data analytics solution did not qualify as "Fees for Technical Services" (FTS) under the Income Tax Act, 1961 and the India-US DTAA. The assessee had submitted a Tax Residency Certificate (TRC) and offered the income generated in India as business income in the resident country, as required by law. Consequently, the grounds of appeal nos. 1 to 6 filed by the assessee were allowed. Regarding TDS credit, the ITAT directed the Assessing Officer to verify and allow the same as per law.
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