Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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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