Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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The ITAT allowed the taxpayer's appeal, holding that the taxpayer, a Singapore resident portfolio company wholly owned by a sovereign investment vehicle, possessed sufficient economic substance, independent management and operational control in Singapore and therefore did not qualify as a conduit or shell. The Tribunal found the pre-1/4/2017 share acquisition qualified for taxation solely in Singapore under Article 13(4)/(4A) of the India-Singapore DTAA and that the subsequent sale to an unrelated foreign purchaser was a genuine commercial realization. Applying Article 24A(1)-(2) (PPT), the Tribunal concluded that obtaining a treaty benefit was not one of the principal purposes and accordingly upheld the treaty exemption of the capital gain.
The ITAT allowed the taxpayer's appeal, holding that the taxpayer, a Singapore resident portfolio company wholly owned by a sovereign investment vehicle, possessed sufficient economic substance, independent management and operational control in Singapore and therefore did not qualify as a conduit or shell. The Tribunal found the pre-1/4/2017 share acquisition qualified for taxation solely in Singapore under Article 13(4)/(4A) of the India-Singapore DTAA and that the subsequent sale to an unrelated foreign purchaser was a genuine commercial realization. Applying Article 24A(1)-(2) (PPT), the Tribunal concluded that obtaining a treaty benefit was not one of the principal purposes and accordingly upheld the treaty exemption of the capital gain.
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