Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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