Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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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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