Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Under Article 8 of the India-France DTAA, collection charges retained from PSF/UDF were treated as an incentive for timely remittance and were held not directly connected with the operation of aircraft in international traffic, so the assessee's exclusion claim failed. Technical handling income from IATP/Non-IATP members was treated as profits from participation in a pool and retained its Article 8 character. Interest on fixed deposits from surplus or security funds connected with airline operations was treated as interest on funds connected with aircraft operations and covered by Article 8. Commission from the domestic leg of international travel was also treated as directly connected with international traffic and fell within Article 8.
Under Article 8 of the India-France DTAA, collection charges retained from PSF/UDF were treated as an incentive for timely remittance and were held not directly connected with the operation of aircraft in international traffic, so the assessee's exclusion claim failed. Technical handling income from IATP/Non-IATP members was treated as profits from participation in a pool and retained its Article 8 character. Interest on fixed deposits from surplus or security funds connected with airline operations was treated as interest on funds connected with aircraft operations and covered by Article 8. Commission from the domestic leg of international travel was also treated as directly connected with international traffic and fell within Article 8.
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