Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Certificate under Section 195 was ordered rectified: a previously issued 5.25% certificate is directed to be treated as a Nil rate certificate and the competent authority must issue an amended Nil rate certificate within seven days on production of this order. Further directions require future Nil rate certificates for FY 2025 26 and subsequent years to be issued within 30 days of application, subject to a recorded finding that the applicant has a Permanent Establishment in India; such an adverse finding requires prior notice. Applicants must make full and true disclosure in annual applications.
Certificate under Section 195 was ordered rectified: a previously issued 5.25% certificate is directed to be treated as a Nil rate certificate and the competent authority must issue an amended Nil rate certificate within seven days on production of this order. Further directions require future Nil rate certificates for FY 2025 26 and subsequent years to be issued within 30 days of application, subject to a recorded finding that the applicant has a Permanent Establishment in India; such an adverse finding requires prior notice. Applicants must make full and true disclosure in annual applications.
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