Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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ITAT ruled on long-term capital gains (LTCG) taxation for shares acquired before 01.04.2017 under India-Singapore DTAA. The tribunal held that LTCG from share transfer cannot be taxed in India for pre-specified shares. The assessee can choose treaty benefits for each transaction separately and is entitled to carry forward long-term capital loss (LTCL) under domestic tax provisions. The appellate authority found merit in the assessee's argument regarding carry forward of LTCL, noting the issue was debatable and the Assessing Officer incorrectly disallowed LTCL carry forward. Consequently, the assessee's appeal was allowed, permitting LTCL carry forward and treaty benefits application.
ITAT ruled on long-term capital gains (LTCG) taxation for shares acquired before 01.04.2017 under India-Singapore DTAA. The tribunal held that LTCG from share transfer cannot be taxed in India for pre-specified shares. The assessee can choose treaty benefits for each transaction separately and is entitled to carry forward long-term capital loss (LTCL) under domestic tax provisions. The appellate authority found merit in the assessee's argument regarding carry forward of LTCL, noting the issue was debatable and the Assessing Officer incorrectly disallowed LTCL carry forward. Consequently, the assessee's appeal was allowed, permitting LTCL carry forward and treaty benefits application.
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