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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Exchange of information under bilateral tax treaties was interpreted to require applicability to information relating to fiscal years beginning after the protocol's specified date, so the IndiaSwiss Article 26 applies only to fiscal years commencing after 01.04.2011 and the IndiaHong Kong Protocol clause 5(c) permits information only for fiscal years or taxable events after 30.11.2018 (effectively FY 2019-20/AY 2020-21). Consequently, a revenue authority could not compel information for the Assessment Year 2017-18, the reference to the Foreign Tax and Tax Research Division was held improper, and the assessing officer cannot claim the one-year extension of limitation under the explanation to the Income Tax Act.
Exchange of information under bilateral tax treaties was interpreted to require applicability to information relating to fiscal years beginning after the protocol's specified date, so the IndiaSwiss Article 26 applies only to fiscal years commencing after 01.04.2011 and the IndiaHong Kong Protocol clause 5(c) permits information only for fiscal years or taxable events after 30.11.2018 (effectively FY 2019-20/AY 2020-21). Consequently, a revenue authority could not compel information for the Assessment Year 2017-18, the reference to the Foreign Tax and Tax Research Division was held improper, and the assessing officer cannot claim the one-year extension of limitation under the explanation to the Income Tax Act.
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