Double taxation avoidance treaty limits source taxation via PE attribution and prescribes credit relief for cross border income.
The Agreement defines covered taxes and residence, adopts a permanent establishment standard (including project and dependent agent PEs), limits source state taxation of business profits to amounts attributable to a PE with expense deductions under domestic law, and confines international transport profits to the enterprise's residence. It caps withholding rates on dividends, interest and royalties, prescribes source rules for capital gains in specified circumstances, assigns pension and most other income to the state of residence, provides student concessions, employs the credit method to eliminate double taxation, and includes exchange of information and an anti abuse provision.

Characterisation of adjusted licence fee as business receipt - treated as linked to cargo handling, not separate rental income.
The recovery of licence fee/rent by adjustment against charges payable to a cargo handling contractor was part of the contractual charge structure for cargo handling and was inextricably linked to the carrier's cargo handling activity, thereby constituting an element of that business's income stream rather than a separate rental business.

Issuance of Special Bonds compensates oil firms for under recoveries; transferability and repo use allowed, RBI LAF discretionary.
The Government issued 8.20% Special Bonds at par to three oil marketing companies as compensation for estimated under recoveries; the bonds are transferable and repo eligible, with RBI Liquidity Adjustment Facility inclusion at the Bank's discretion. Bank and insurance investments will not be reckoned as eligible government securities for statutory requirements, though insurance investments may qualify as "other Approved Securities" under IRDA (Investment) Regulations, 2000, and provident, gratuity and superannuation fund investments will be treated as eligible under a Ministry of Finance administrative order.

Deduction under section 43B: payment basis does not override accrual accounting; advance tax payments may not be deductible.
Section 43B permits deduction on actual payment only if the expenditure is otherwise allowable under the general deduction provision read with the taxpayer's accounting method. Under mercantile (accrual) accounting, an advance payment of sales tax for a later period is not an accrued expense and thus is not deductible under the general deduction and accounting rules; payment alone does not render it allowable under section 43B.

Tax collection growth driven by strengthening of tax deduction at source and improved compliance despite global slowdown.
Net direct tax collections rose sharply in the first seven months, driven by stronger corporate and personal income tax receipts and a CBDT strategy emphasizing Tax Deduction at Source and enhanced compliance; TDS and self-assessment tax showed major increases while Securities Transaction Tax fell and advance tax receipts displayed divergent sectoral performance.