Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT ruled on multiple taxation issues: (1) Short-term capital gains (STCG) from rights entitlement are exempt under Article 13(6) of India-Ireland DTAA, rejecting tax authority's denial. (2) Assessee permitted to set off STCG from non-STT paid shares against short-term capital loss (STCL) from STT paid shares, overturning tax officer's restrictive interpretation of section 70. (3) Directed tax authority to consider TDS credit rectification petition and refund claim, ensuring assessee receives procedural fairness and opportunity to be heard.
ITAT ruled on multiple taxation issues: (1) Short-term capital gains (STCG) from rights entitlement are exempt under Article 13(6) of India-Ireland DTAA, rejecting tax authority's denial. (2) Assessee permitted to set off STCG from non-STT paid shares against short-term capital loss (STCL) from STT paid shares, overturning tax officer's restrictive interpretation of section 70. (3) Directed tax authority to consider TDS credit rectification petition and refund claim, ensuring assessee receives procedural fairness and opportunity to be heard.
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