Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
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ITAT determined that for transactions of share alienation during FY 2015-16, pre-amended India-Singapore DTAA provisions apply. The tribunal found insufficient evidence regarding Singapore tax treatment, leaving the second condition of Article 24(1) unresolved. Ultimately, the assessee was deemed eligible for Article 13(4) benefits, with taxing rights attributed to Singapore for capital gains on shares acquired before 01 April 2017. The tribunal directed the Assessing Officer to allow carry forward of short-term capital losses and apply treaty benefits for gross short-term capital gains, effectively allowing the additional ground of appeal.
ITAT determined that for transactions of share alienation during FY 2015-16, pre-amended India-Singapore DTAA provisions apply. The tribunal found insufficient evidence regarding Singapore tax treatment, leaving the second condition of Article 24(1) unresolved. Ultimately, the assessee was deemed eligible for Article 13(4) benefits, with taxing rights attributed to Singapore for capital gains on shares acquired before 01 April 2017. The tribunal directed the Assessing Officer to allow carry forward of short-term capital losses and apply treaty benefits for gross short-term capital gains, effectively allowing the additional ground of appeal.
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