In the present case, though the assessee was to receive monthly alimony which was to be taxable in the each year from conclusion of divorce agreement but in this case monthly payments were not received and, therefore, were not offered tax.
This public discussion draft includes proposals for additions and changes to the Commentary on the OECD Model Tax Convention resulting from the work of that subgroup. These proposals have recently been presented to the Working Party for discussion with a view to their possible inclusion in the OECD Model Tax Convention.
The arm’s length result under the TNMM is determined to the net profit margin of a comparable transactions under a comparable circumstances and the profitability derived from uncontrolled party engaged in similar business activity under similar circumstances are to be analysed.
Here in the present case, there is no linkage or nexus between the funds borrowed by assessee and the impugned investments, hence, no interest expenditure can be disallowed by mechanically applying the Provisions of Rule 8D of the Rules.
it would be wholly unreasonable to deduct tax at source on an amount which has not accrued to the Petitioner as income during the financial year in question, the entitlement of the Petitioner being contingent on the outcome of the challenge to the arbitral award.
Article deal with 1. Non availability of credit in case of inter-state purchases and in certain other cases 2. When dealer is not entitled to input credit? Manufacturer will be entitled to credit of tax paid on inputs used by him in manufacture. A trader (dealer) will be entitled to get credit of tax on goods which he has purchased for re-sale.
Acceptance of return is general approach of government: It can be said that acceptance of returns filed by assessee is general approach of the GOI. This is evident from the fact that majority of returns are accepted as per self assessment and they get finality once an intimation is prepared and accordingly tax is demanded or refund is issued.
