In re Mallelli Venkateswara Rao (GST AAR Andhra Pradesh) What is a support service in relation to the above had been defined by means of an explanation to the same entry. And the explanation had employed the word ‘mean’ which is restrictive in nature. Thus what is given in explanation shall only mean as support […]
In view of Section 90(2) of the Act and clause 4(b) of Article 12 of the Treaty, the provisions of this Act would stand applicable only where fees for included services taxable only if there is a make available technical knowledge. In the case in hand finding of fact that has been returned by the ITAT, there is no make available of the technical knowledge, therefore, the provisions of the Income Tax Act would not stand attracted in the transactions in question.
Where TPO was not convinced with the benchmarking of international transaction of assessee, he should have independently benchmarked the arm’s length price of royalty payment by adopting any one of the prescribed methods which he had failed to do and determined arm’s length price at nil on purely ad–hoc basis without assigning any valid and acceptable reason, therefore, the addition made on account of adjustment made to the arm’s length price of royalty payment was to be deleted.
Adani Enterprise Ltd. Vs DCIT (ITAT Ahmedabad) We notice that no time limit has been prescribed for passing order under s.206C of the Act. The CIT(A) has assumed that in the absence of statutory time limit provided, the provisions of Section 201(3) of the Act providing time limit for deduction of tax at source can […]
As nature of “interest subsidy and power” depends on the purpose for which it was given, hence, in assessee’s case it was ‘capital’ in nature not liable to tax because the entire reason behind receiving the subsidy was setting up of plant in the backward region of West Bengal, namely, Bankura.
Article explains Eligibility for Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (LDRS) and amount of Tax, Interest and Penalty payable. Sl. No Situation 1 Situation 2 (to be read with Situation 1) Eligible for LDRS (Yes or No) Category % of Amount of Duty payable (See Note1 below the table) Relevant clause (s) in Finance […]
Tariff Notification No. 49/2019-CUSTOMS (N.T.) in respect of Fixation of Tariff Value of Edible Oils, Brass Scrap, Poppy Seeds, Areca Nut, Gold and Sliver
Reg. Appointment of CAA by Pr. DGRI vide Notification No. 28/2019-Customs (N.T./CAA/DRI) Dated New Delhi, dated the 09th July, 2019. Government of India Ministry of Finance (Department of Revenue) Central Board of Indirect Taxes and Customs Directorate of Revenue Intelligence Notification No. 28/2019-Customs (N.T./CAA/DRI) New Delhi, dated the 09th July, 2019 S.O. 2451(E).– In pursuance of […]
One of the most globally recognized sector i.e. the real estate sector ranks 3rd among the 14 major sectors in the country in terms of direct, indirect and induced effects in all sectors of the economy. The Real estate sector is an important pillar of the economy fulfilling the demand for infrastructure in the country. […]
Analysis of Finance Bill (02) 2019 The major proposed amendment by Finance bill (02) 2019. Few amendments which are not so important are not covered. 1. Amendment in Section 2(19AA) (Definition) One of the condition to qualify the definition of demerger is “The resulting company will record the property and liability of the undertaking/s at […]
