Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
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Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Buy-back of shares by an Indian subsidiary was treated as a corporate reorganisation because the transaction involved transfer of shares within the same corporate group and changed the form of the foreign shareholder's interest without altering its underlying ownership. Relying on the understanding of corporate restructuring reflected in professional guidance and the object of Article 13(5) of the India-Netherlands DTAA, the Tribunal held that the resulting gains fell within that treaty provision. The gains were therefore not taxable in India, and the assessee's appeal was allowed by majority.
Buy-back of shares by an Indian subsidiary was treated as a corporate reorganisation because the transaction involved transfer of shares within the same corporate group and changed the form of the foreign shareholder's interest without altering its underlying ownership. Relying on the understanding of corporate restructuring reflected in professional guidance and the object of Article 13(5) of the India-Netherlands DTAA, the Tribunal held that the resulting gains fell within that treaty provision. The gains were therefore not taxable in India, and the assessee's appeal was allowed by majority.
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