Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Article 24(2) of the India-Netherlands DTAA does not entitle an Indian permanent establishment of a Netherlands bank to domestic-company tax rates where it remains a foreign company; the section 90 Explanation treats a higher foreign-company rate as non-discriminatory. Article 7's separate-enterprise fiction requires consistent treatment: interest remitted by an Indian PE to its overseas head office or branches is taxable in India, requires withholding, and is disallowed if withholding fails; interest received from them is taxable PE business income. ATMs qualify as computers for depreciation based on functional utility. Accounting Standard 19 does not govern tax characterisation; vehicle hiring payments remain deductible revenue expenditure absent an intention to acquire ownership.
Article 24(2) of the India-Netherlands DTAA does not entitle an Indian permanent establishment of a Netherlands bank to domestic-company tax rates where it remains a foreign company; the section 90 Explanation treats a higher foreign-company rate as non-discriminatory. Article 7's separate-enterprise fiction requires consistent treatment: interest remitted by an Indian PE to its overseas head office or branches is taxable in India, requires withholding, and is disallowed if withholding fails; interest received from them is taxable PE business income. ATMs qualify as computers for depreciation based on functional utility. Accounting Standard 19 does not govern tax characterisation; vehicle hiring payments remain deductible revenue expenditure absent an intention to acquire ownership.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
