Tenet Tax Daily March 08 2017
When activities relating to construction or installation are specifically covered under article 5(3) of India-Singapore DTAA, then one need not to go in article 5(6) and, therefore, activity of assessee which is purely installation services has to be scrutinized under article 5(3) only and not within article 5(6)
Whether in terms of relevant clauses of DTAA between India-Italy and India-Japan, where payments fall within purview of Independent Personal services then, even if, they are treated as Fees for technical fee or Fees for included services, such income of non-resident shall be liable to be taxed under Article governing Independent Personal services and not as Fee for technical services
Tenet Tax Daily March 07 2017
Once raw material quantity that did not appear in regular books of account was discovered and could be inferred as a result of search, onus lay upon assessee to furnish full particulars as to cost of that raw material or average cost
Tenet Tax Daily March 06 2017
Section 80-IB(10) relief to be allowed only when return is filed on or before due date given under section 139(1)
Tenet Tax Daily March 04 2017
Payment made for connectivity facility for sending bulk SMS couldn’t be held as royalty: Mumbai ITAT
Tenet Tax Daily March 03 2017
Section 153 not to be applied in respect of proceedings covered under ambit of sec. 144C
Tenet Tax Daily March 02 2017
Failure of assessee to disclose capital gains on basis of sec. 50C would invite reassessment
Tenet Tax Daily March 01 2017
Liaison office of GE India held as agency PE as it has authority to conclude contract on behalf of GE overseas
Tenet Tax Daily February 27 2017
No tax on sum received by Dutch Airlines for line maintenance facilities provided to other Airlines
Tenet Tax Daily February 25 2017
Sec. 43B applies to both employee and employer’s contribution to PF and ESI
Tenet Tax Daily February 24 2017
Payment made to access online database couldn’t be held as royalty
Tenet Tax Daily February 23 2017
No income can be attributable to PE which is remunerated at ALP
Tenet Tax Daily February 22 2017
Rental income earned by treating property as a capital asset would be assessable as ‘income from house property’
Tenet Tax Daily February 21 2017
Payment for testing, trial operation and commissioning work would attract sec. 194C TDS and not sec. 194J TDS
Tenet Tax Daily February 20 2017
Margins of both on-site and off-site services could not be aggregated while computing ALP: ITAT
Tenet Tax Daily February 18 2017
AO directed to ascertain amount of unpaid tax and interest of defaulting company for recovery under sec. 179
Tenet Tax Daily February 16 2017
Rajkot ITAT taxes capital gains in year of registration of sale agreement
Tenet Tax Daily February 15 2017
AO couldn’t make reassessment for unexplained investment merely on basis of roving inquiry
Tenet Tax Daily February 14 2017