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...
Dividend distribution tax paid on dividends distributed to non-resident shareholders was treated as falling within the more beneficial treaty rate under the India-Japan and India-Thailand DTAA, because the tax was viewed in substance as a tax on dividend income of the shareholder. Following binding precedent, the ITAT accepted the assessee's challenge to the higher domestic rate for AY 2017-18 and applied the same view to AY 2018-19. It also held that corporate club membership fees were allowable business expenditure under section 37 and not personal expenditure, as the membership served business purposes and the Revenue's authorities were distinguishable. Both appeals were allowed.
Dividend distribution tax paid on dividends distributed to non-resident shareholders was treated as falling within the more beneficial treaty rate under the India-Japan and India-Thailand DTAA, because the tax was viewed in substance as a tax on dividend income of the shareholder. Following binding precedent, the ITAT accepted the assessee's challenge to the higher domestic rate for AY 2017-18 and applied the same view to AY 2018-19. It also held that corporate club membership fees were allowable business expenditure under section 37 and not personal expenditure, as the membership served business purposes and the Revenue's authorities were distinguishable. Both appeals were allowed.
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