Revenue authority mandates using scheme-specific reversal procedures, not revising original entries, for instrument-based trade/customs benefits effec...
Transaction value under s.15(1) governs unrelated sales; valuation between related parties per Rule 28; consignment note required for unregistered rec...
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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