Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
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The SC dismissed the SLP challenging the ITAT's decision that DTAA benefits apply in proceedings under section 201 of the Act, affirming that payments made to a foreign entity for interconnectivity charges do not constitute royalty, FTS, or business profits taxable in India. The court held that as the facilities are located outside India and the agreement is with a Belgium entity lacking Indian presence, Indian tax authorities lack jurisdiction to tax income from extraterritorial sources. The assessee is not required to perform the impossible by disregarding DTAA provisions. Pending applications were disposed of accordingly.
The SC dismissed the SLP challenging the ITAT's decision that DTAA benefits apply in proceedings under section 201 of the Act, affirming that payments made to a foreign entity for interconnectivity charges do not constitute royalty, FTS, or business profits taxable in India. The court held that as the facilities are located outside India and the agreement is with a Belgium entity lacking Indian presence, Indian tax authorities lack jurisdiction to tax income from extraterritorial sources. The assessee is not required to perform the impossible by disregarding DTAA provisions. Pending applications were disposed of accordingly.
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