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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An individual's residential status for AY 2020-21 was determined under s.6(1)(c) as the individual exceeded both thresholds (≥365 days in preceding four years and ≥60 days in the relevant year), and the relaxation to 182 days under Explanation 1(a)/(b) was held inapplicable because it is confined to specified cases (leaving India or non-residents "being outside India") and cannot be extended to ordinary visits; accordingly, the individual was held resident in India. Applying Article 4 India-Singapore DTAA, the "permanent home/centre of vital interests" and habitual abode factors showed closer economic ties with India, and nationality also supported India; treaty tie-breaker therefore treated the individual as India resident. Objection to jurisdiction based on s.143(2) notice issuance was rejected due to participation in assessment proceedings. - ITAT
An individual's residential status for AY 2020-21 was determined under s.6(1)(c) as the individual exceeded both thresholds (≥365 days in preceding four years and ≥60 days in the relevant year), and the relaxation to 182 days under Explanation 1(a)/(b) was held inapplicable because it is confined to specified cases (leaving India or non-residents "being outside India") and cannot be extended to ordinary visits; accordingly, the individual was held resident in India. Applying Article 4 India-Singapore DTAA, the "permanent home/centre of vital interests" and habitual abode factors showed closer economic ties with India, and nationality also supported India; treaty tie-breaker therefore treated the individual as India resident. Objection to jurisdiction based on s.143(2) notice issuance was rejected due to participation in assessment proceedings. - ITAT
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