#Section 144C
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508 articlesIncome Tax

Income Tax
Centralised service income not taxable under Article 12(4)(a) of India-USA DTAA as FTS/ FIS
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Transfer pricing adjustment @0.6% as arm’s length rate for corporate guarantee fee directed
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Post existence of PE, expense incurred by PE can be set off against connected income
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Foreign Currency Convertible Bond expenses included as FCCB premium expense is allowable
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Addition towards disallowance u/s 14A to book profit computed u/s 115JB is unsustainable
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Disallowance u/s 14A untenable on mechanical application of rule 8D
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Expenditure towards ESOP is allowable deduction u/s 37
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Assessment order passed on a non-existent company is null and void
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Chapter X cannot be invoked for making TP adjustment in case of AMP expenses
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Capitalized Expense shouldn’t be considered for computation of proportionate TP adjustment
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Interest on FCCDs is to be computed by applying LIBOR plus 200 points
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Business profit not taxable in India in absence of any permanent establishment
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Writ not entertained as effective alternative remedy u/s 144C available
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