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...
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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