Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
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 ...
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Fiscal transparency of a UK partnership requires Indian-source income to be tested partner by partner for treaty entitlement. Article 4(1)(b) of the India-UK DTAA limits protection to the share taxed as income of a UK resident, whether in the partnership's or partners' hands; it does not bar non-UK resident partners from invoking India's treaty with their own residence State. Domestic recognition of the partnership does not establish a single treaty residence. Treaty claims require residence certificates and prescribed information. Legal-professional services are not automatically fees for technical services merely because India-UK treaty relief is unavailable; their characterisation must satisfy domestic law and the applicable treaty's income article, including relevant fixed-base, permanent-establishment, or presence conditions.
Fiscal transparency of a UK partnership requires Indian-source income to be tested partner by partner for treaty entitlement. Article 4(1)(b) of the India-UK DTAA limits protection to the share taxed as income of a UK resident, whether in the partnership's or partners' hands; it does not bar non-UK resident partners from invoking India's treaty with their own residence State. Domestic recognition of the partnership does not establish a single treaty residence. Treaty claims require residence certificates and prescribed information. Legal-professional services are not automatically fees for technical services merely because India-UK treaty relief is unavailable; their characterisation must satisfy domestic law and the applicable treaty's income article, including relevant fixed-base, permanent-establishment, or presence conditions.
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