#Section 144C
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543 articlesIncome Tax
Income Tax
Receipts from operation of ships in international traffic is exempt in terms of India-Singapore DTAA
Income Tax
Income Tax
Transfer of Renewable Energy Certificate is capital and not taxable as business income
Income Tax
Income Tax
Pre-clinical laboratory services by non-resident to Indian Customers not chargeable to tax in India
Income Tax
Income Tax
Determination of ALP of intra group services as NIL not sustained as reasonable documents maintained
Income Tax
Income Tax
Rate at which loan taken by Appellant cannot be taken as internal CUP to benchmark loan given to AE
Income Tax
Income Tax
Arriving at Arm’s Length Price as NIL without giving contrary finding is unsustainable
Income Tax
Income Tax
AO not empowered to withdraw or modify or substitute order passed u/s 143(3) with another order
Income Tax
Income Tax
Centralised service income not taxable under Article 12(4)(a) of India-USA DTAA as FTS/ FIS
Income Tax
Income Tax
Transfer pricing adjustment @0.6% as arm’s length rate for corporate guarantee fee directed
Income Tax
Income Tax
Post existence of PE, expense incurred by PE can be set off against connected income
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Income Tax
Foreign Currency Convertible Bond expenses included as FCCB premium expense is allowable
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Income Tax
Addition towards disallowance u/s 14A to book profit computed u/s 115JB is unsustainable
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Income Tax
Disallowance u/s 14A untenable on mechanical application of rule 8D
Income Tax
Income Tax
