PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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Taxability of capital gains arising on sale of equity shares/CCDs by a Singaporeincorporated subsidiary was examined under the India-Singapore DTAA. The tribunal found the entity to be a shell/conduit lacking commercial substance-no office, employees, or operating costs-and held that mere possession of a tax residency certificate is insufficient. Applying the substanceoverform approach, the limitationonbenefits (LOB) provision was attracted, denying treaty relief. Consequentially, the capital gains were held taxable in India under the source rule and treaty benefits under the India-Singapore DTAA were disallowed.
Taxability of capital gains arising on sale of equity shares/CCDs by a Singaporeincorporated subsidiary was examined under the India-Singapore DTAA. The tribunal found the entity to be a shell/conduit lacking commercial substance-no office, employees, or operating costs-and held that mere possession of a tax residency certificate is insufficient. Applying the substanceoverform approach, the limitationonbenefits (LOB) provision was attracted, denying treaty relief. Consequentially, the capital gains were held taxable in India under the source rule and treaty benefits under the India-Singapore DTAA were disallowed.
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