Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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...
ITAT set aside the assessments computed under s.44BB and held that the India-Norway DTAA applies; paras 2-3 of Article 21 are inapplicable because the taxpayer, a Norway tax resident providing vessels for transportation on bareboat charter to entities engaged in seabed exploration, is not itself conducting exploration/exploitation. Article 21(4) governs computation of income for enterprises operating vessels, and the AO was directed to compute the taxpayer's total income and tax liability in accordance with Article 21(4) of the India-Norway treaty. Grounds raised by the taxpayer were allowed and the matter remitted to the AO for recomputation consistent with this ruling.
ITAT set aside the assessments computed under s.44BB and held that the India-Norway DTAA applies; paras 2-3 of Article 21 are inapplicable because the taxpayer, a Norway tax resident providing vessels for transportation on bareboat charter to entities engaged in seabed exploration, is not itself conducting exploration/exploitation. Article 21(4) governs computation of income for enterprises operating vessels, and the AO was directed to compute the taxpayer's total income and tax liability in accordance with Article 21(4) of the India-Norway treaty. Grounds raised by the taxpayer were allowed and the matter remitted to the AO for recomputation consistent with this ruling.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
