Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Dividend distribution tax on payments to a non-resident shareholder was examined against the India-Netherlands DTAA, with the Tribunal noting that treaty rate restriction may apply and that the matter required verification of the applicable treaty and domestic rate comparison; the issue was remitted to the Assessing Officer for fresh adjudication after due examination. Transfer pricing adjustment on management fees was also sent back for fresh consideration because the assessee's cost-benefit material and the benchmarking approach, including aggregation, had not been fully examined; the Dispute Resolution Panel was directed to reconsider the issue with adequate opportunity to the assessee.
Dividend distribution tax on payments to a non-resident shareholder was examined against the India-Netherlands DTAA, with the Tribunal noting that treaty rate restriction may apply and that the matter required verification of the applicable treaty and domestic rate comparison; the issue was remitted to the Assessing Officer for fresh adjudication after due examination. Transfer pricing adjustment on management fees was also sent back for fresh consideration because the assessee's cost-benefit material and the benchmarking approach, including aggregation, had not been fully examined; the Dispute Resolution Panel was directed to reconsider the issue with adequate opportunity to the assessee.
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