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...
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...
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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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