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I-T - If assessee has proved source of investment in share application money of foreign entity, and also explained source of source of funds, the...
I-T - If assessee has remained in India in last four years for more than 365 days and in relevant previous year for more than 182 days, then only...
I-T - Income accrues at place where title to goods passes to buyers on payment of price: ITAT...
DTAA - Merely because non-resident entity which had no PE in India, had applied for lower tax deduction certificate u/s 197, that in itself is no...
DTAA - Tax demand cannot be raised against assessee was non resident of India in relevant period & who offered income for tax & paid tax thereon ...
https://taxindiainternational.com/case_lawDesc.php?qwer43fcxzt=MTQ1MDM= ...
I-T - Even if payments were to be assumed to be dividend, then liability to pay DDT thereon could have only been foisted upon company which had d...
DTAA - Notification u/s 90(1) is necessary & mandatory condition for Court, Authority or Tribunal to give effect to DTAA or any protocol changing...
I-T - Second unit of contract manufacturer of overseas entity, formed by transfer of machinery previously used, is not eligible to claim deductio...
I-T - Except in case of reference to TPO, extended time limit of 12 months for completion of assessment is not available in case of Non-Resident ...
DTAA - Deployment of 'sofware' lacks physical attributes which underlie and constitute integral part of concept of Permanent Establishment: HC...
DTAA - Subscription fee charged by non-resident entity for granting access to database would clearly not amount to transfer of 'right to use copy...
TP - Overseas AEs can be treated as tested parties, after considering global transfer pricing report of foreign AEs: ITAT...
I-T - Since no business activity is carried out by assessee during relevant period through LO and no expat employee were engaged by assessee at L...
DTAA - Non-resident assessee is eligible for choosing beneficial provisions provided under domestic law and carry forward same without setting of...
DTAA - Rule 128(9) does not preclude assessee from claiming Foreign Tax Credit (FTC) in case of delay in filing ITR, as the FTC is a vested right...
I-T - Payment made overseas for services rendered abroad, is not deemed income u/s 9, and hence not liable to TDS u/s 195: ITAT...
DTAA - Compensation received by non-resident assessee, pursuant to Arbitral Award, for non-payment of dues for offshore supplies made, would have...
INTL - Re-assessment in cases involving tax amounts under Rs 50 Lakhs have to be completed within 3 years, failing which any order is barred by l...
TP - Assessee's claim against reversal of provision for inventory written off due to obsolescence, is allowable, since the same is offered to tax...
 
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