ITAT Delhi allows Hyosung Corporation to set off Indian Permanent Establishment (PE) business losses against Fees for Technical Services (FTS) income. The ruling clarifies that under the Income Tax Act, a foreign entity’s income is aggregated for taxation, permitting inter-head adjustments despite DTAA classifications.
Explore Bombay High Court’s landmark ruling on customs jurisdiction versus international treaty obligations under ASEAN-India FTA, clarifying enforcement of domestic law over unincorporated treaty provisions
ITAT Chennai rules Section 6 of the Income Tax Act prevails over a Tax Residency Certificate (TRC) for determining Indian residency. Global income taxable if an individual meets the specified days in India, irrespective of TRC.
Court rules income from white button mushroom cultivation under controlled conditions qualifies as agricultural income, exempt from tax, emphasizing ‘soil’ as ‘land’ and purpose over strict classification.
