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DTAA - Purpose of Art 25(1) of DTAA is limited to elimination of double taxation and cannot be interpreted to impose restrictions of domestic law...
I-T - Apportionment of contract price into different cost centers and milestones, as pre-requisite of tender conditions, does not automatically r...
I-T - If right to show cricket matches is confined to live telecast and payment made is only for matches held in series and not subsequent matche...
I-T - Once receipts fall within definition of FTS under DTAA as well as domestic law, it becomes immaterial whether assessee has PE in India or n...
I-T - Mere fact that assessee earned commission from Indian accommodations does not, by itself, create Permanent Establishment: ITAT...
I-T - Payment received by non-resident entity for granting non-exclusive license for broadcasting of cinematographic films does not constitute ro...
I-T - Assessee can increase losses by claiming provision for warranties as per note no 11 of audited financial statements: ITAT...
I-T -Denial of Foreign Tax Credit solely due to delayed filing of Form 67 is not tenable: ITAT ...
INTL - Denial of Foreign Tax Credit solely based on a clerical & unintentional error in Form 67 unsustainable, considering that technical errors ...
I-T - Profits derived from transportation of passengers under code sharing arrangement is to be treated as profits from operation of aircrafts: I...
TP- ICDS-I principles take precedence over Ind-AS, requiring use of cost price or acquisition cost of investments: ITAT ...
TP - If final assessment order passed by AO u/s 143(3) r.w.s. 144C(13) r.w.s. 144B is beyond upper time limit provided u/s 153(1) and Section 153...
I-T - Attribution of revenue to a Permanent Establishment does not limit deduction of expenses incurred to earn that revenue: HC...
I-T - Assessee's statutory right to have objections adjudicated by DRP u/s 144C cannot be defeated by bona fide procedural error, such as filing ...
I-T - Where assessee, eligible u/s 144C has filed objections to draft assessment order before DRP, AO cannot lawfully pass final assessment order...
I-T - Authority deciding applications u/s 197 is obligated to decide as per provisions of Income Tax Act, and with due regard to treaties between...
I-T - If non-resident's income from mineral oil exploration activities qualifies as FTS or Royalty and is connected to Permanent Establishment in...
TP - Failure of TPO to supply copies of agreements that form basis of its findings constitutes violation of principles of natural justice: HC...
I-T - If operation of airline services is exempt from taxation under relevant DTAA & Income Tax Act, and if there is no outstanding tax demand, c...
I-T - Scheme of Section 144C is designed to protect the principles of natural justice and that administrative mechanisms should be put in place t...
 
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