Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Denial of charitable exemption under section 11 does not by itself justify taxing an educational trust's entire gross receipts. Taxable income must ordinarily reflect real income, determined after verification and allowance of genuine expenditure otherwise admissible in law, unless a provision requires taxation on a gross basis. The computation was restored to the assessing authority to examine the books and determine net taxable income after verifying the claimed expenditure; the appeal was partly allowed for statistical purposes.
Denial of charitable exemption under section 11 does not by itself justify taxing an educational trust's entire gross receipts. Taxable income must ordinarily reflect real income, determined after verification and allowance of genuine expenditure otherwise admissible in law, unless a provision requires taxation on a gross basis. The computation was restored to the assessing authority to examine the books and determine net taxable income after verifying the claimed expenditure; the appeal was partly allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
