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 allowed the Taxpayer's appeal, holding that Article 8 of the India-UAE DTAA governs the entire freight receipts from shipping operations, irrespective of whether earnings arise from feeder vessels or from ships in international traffic. The Tribunal concluded that inland haulage charges are inextricably linked to the operation of ships in international traffic and form an integral part of the profit from shipping business under Article 8. Consequently, such receipts fall within the DTAA allocation and are not taxable in India under section 44B of the IT Act. The Revenue's appeal was dismissed in respect of the shipping income and related inland haulage charges.
ITAT allowed the Taxpayer's appeal, holding that Article 8 of the India-UAE DTAA governs the entire freight receipts from shipping operations, irrespective of whether earnings arise from feeder vessels or from ships in international traffic. The Tribunal concluded that inland haulage charges are inextricably linked to the operation of ships in international traffic and form an integral part of the profit from shipping business under Article 8. Consequently, such receipts fall within the DTAA allocation and are not taxable in India under section 44B of the IT Act. The Revenue's appeal was dismissed in respect of the shipping income and related inland haulage charges.
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