ESOP expenditure allowed as FMV difference; long-term capital gain issue sent back for collector rate determination; deferred income additions disallo...
Appeal allowed; impugned order quashed as regulator failed to prove nexus or manipulative scheme; sale genuine - s.12A(a)-(c), Regs 3(a)-(d),4(1),4(2)...
Appellant's ring-back tone service held OIDAR, taxable domestically for 01.07.2012-31.07.2016; liability confirmed, penalties vacated, remanded for re...
The HC allowed the special civil applications, held that the appellants-assessee are entitled to the benefit of Article 8 of the India-Singapore DTAA in respect of profits from operation of ships in international traffic at Indian ports, and quashed the Tribunal's order restoring the matter to the Assessing Officer. The Court accepted the certificate dated 09.01.2013 issued by the Singapore tax authority (IRAS) as establishing that such income was taxable in Singapore on an accrual basis; Article 24 of the DTAA was held inapplicable on these facts. Assessment orders are set aside and the tax appeals are allowed in favour of the assessee and against the Revenue.
The HC allowed the special civil applications, held that the appellants-assessee are entitled to the benefit of Article 8 of the India-Singapore DTAA in respect of profits from operation of ships in international traffic at Indian ports, and quashed the Tribunal's order restoring the matter to the Assessing Officer. The Court accepted the certificate dated 09.01.2013 issued by the Singapore tax authority (IRAS) as establishing that such income was taxable in Singapore on an accrual basis; Article 24 of the DTAA was held inapplicable on these facts. Assessment orders are set aside and the tax appeals are allowed in favour of the assessee and against the Revenue.
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