Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
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...
Franchise fee paid to secure participation rights in the Indian Premier League was treated as revenue expenditure, as the Tribunal followed coordinate bench decisions in the assessee's own earlier years and found no distinguishing feature or reversal of those rulings. The alternative depreciation claim was therefore academic. On payments to a New Zealand resident talent scout, the Tribunal found the arrangement prima facie consistent with independent personal services under Article 14 of the India-New Zealand DTAA and noted that the 183-day condition was satisfied, but remanded the matter for limited verification of whether the consultant had a fixed base in India. If Article 14 conditions are met, no TDS liability arises.
Franchise fee paid to secure participation rights in the Indian Premier League was treated as revenue expenditure, as the Tribunal followed coordinate bench decisions in the assessee's own earlier years and found no distinguishing feature or reversal of those rulings. The alternative depreciation claim was therefore academic. On payments to a New Zealand resident talent scout, the Tribunal found the arrangement prima facie consistent with independent personal services under Article 14 of the India-New Zealand DTAA and noted that the 183-day condition was satisfied, but remanded the matter for limited verification of whether the consultant had a fixed base in India. If Article 14 conditions are met, no TDS liability arises.
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