Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
The issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
The issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
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