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...
The government notified entry into force of a bilateral agreement and protocol between the two Contracting States to avoid double taxation and prevent fiscal evasion, effective for income arising from the first day of the fiscal year following entry into force. The treaty covers taxes on income, defines residency, permanent establishment rules, and allocation of taxing rights; prescribes withholding limits (dividends 5%/10%, interest 10%, royalties/technical fees 10%), rules on business profits, capital gains, employment income, and exemptions for certain persons. It includes provisions on non-discrimination, mutual agreement procedure, exchange of information, assistance in collection, a principal-purpose anti-abuse rule, and termination mechanics.
The government notified entry into force of a bilateral agreement and protocol between the two Contracting States to avoid double taxation and prevent fiscal evasion, effective for income arising from the first day of the fiscal year following entry into force. The treaty covers taxes on income, defines residency, permanent establishment rules, and allocation of taxing rights; prescribes withholding limits (dividends 5%/10%, interest 10%, royalties/technical fees 10%), rules on business profits, capital gains, employment income, and exemptions for certain persons. It includes provisions on non-discrimination, mutual agreement procedure, exchange of information, assistance in collection, a principal-purpose anti-abuse rule, and termination mechanics.
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