Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Page of 4811
Press 'Enter' after typing page number.
6381 to 6400 of 96208 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The note addresses whether interest received on an income-tax refund from India is taxable in India when earned by a non-resident, focusing on permanent establishment (PE) and treaty relief. Applying the principle that PE must be assessed in the year of receipt, the tribunal followed prior precedent and concluded the assessee had no PE in India and thus could claim DTAA treatment for interest; where the beneficial owner is a resident of the other contracting state the treaty caps source-state tax at 15% of gross interest. The tribunal noted alignment with earlier high court and apex court decisions in reaching this outcome.
The note addresses whether interest received on an income-tax refund from India is taxable in India when earned by a non-resident, focusing on permanent establishment (PE) and treaty relief. Applying the principle that PE must be assessed in the year of receipt, the tribunal followed prior precedent and concluded the assessee had no PE in India and thus could claim DTAA treatment for interest; where the beneficial owner is a resident of the other contracting state the treaty caps source-state tax at 15% of gross interest. The tribunal noted alignment with earlier high court and apex court decisions in reaching this outcome.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
