Tenet Tax Daily October 23 2013
No concealment if an expense was disallowed as two possible views existed on its allowance
No need to establish rendition of services in India to tax FTS as long as payer is a resident
Tenet Tax Daily October 22 2013
Reassessment sets-aside as revenue didn’t establish how project would be deemed as construction PE
Tenet Tax Daily October 21 2013
Cash payments to agents to procure raw materials covered by Rule 6DD; no sec. 40A(3) disallowance
Tenet Tax Daily October 19 2013
Any artwork with life span of less than 6 months couldn’t be deemed as capital expenditure
Tenet Tax Daily October 18 2013
Limit to rectify sec. 155 order begins from date of original order of Settlement Commmission even after minor changes in said order
Tenet Tax Daily October 16 2013
Depreciation allowed on plant which was ready to use but couldn’t be used due to shortage of materials
Tenet Tax Daily October 15 2013
Training expenses of pilots as per requirement of DGCA Rules would not fall under term ‘service make available’ as mentioned in para 4(b) of article 12 of India-USA DTAA
Tenet Tax Daily October 14 2013
Deemed commencement of business if assessee started integeral activities constituting its business
Tenet Tax Daily October 12 2013
Delay in furnishing of TP report condoned as assessee had belief that transaction was not covered under TP
Tenet Tax Daily October 11 2013
Software license for one year held as revenue expenditure since it doesnot confer any enduring benefit
Tenet Tax Daily October 9 2013
Ownership of land isn’t a pre-requisite for a developer to claim sec. 80-IB relief for housing project
Tenet Tax Daily October 8 2013
Reassessment can be made on the basis of info provided by assessee in Voluntary Disclosure Scheme
Tenet Tax Daily October 7 2013
Assessee with no tax incidence but otherwise liable to tax in UAE allowed DTAA benefits
Tenet Tax Daily October 5 2013
Payment to Singaporean Company for executive training isn’t FTS as it falls in exclusive clause of FTS under treaty
Tenet Tax Daily October 4 2013
Business income of NR not taxable if its dependent agent is remunerated on ALP basis and is charged to tax
Tenet Tax Daily October 3 2013
Expenditure disallowed under sec. 14A to be added back for computation of book profit under sec. 115JB
Tenet Tax Daily September 30 2013
Assessment concluded without hearing assessee is invalid even if assessee did not comply with notice for filing of return
Tenet Tax Daily September 28 2013