S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Information technology support services and management services-Neither royalty nor FTS-Not taxable-DTAA-India-France.[S.9(1)(vii), Art.13]
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Information technology support services and management services-Neither royalty nor FTS-Not taxable-DTAA-India-France.[S.9(1)(vii), Art.13]
S. 9(1)(v) : Income deemed to accrue or arise in India-Interest Difference in Form 26AS-Profit and loss account-Interest on external commercial borrowing-DTAA-India-Nether land. [Art. 11(2)]
S. 9(1)(i) : Income deemed to accrue or arise in India – Business connection – Permanent Establishment -Contract for offshore manufacture and supply of equipment and parts to ONGC – DTAA -India –UK. [S. 44BB, Art. 5]
S. 143(1)(a) : Assessment – Intimation – Charitable Trust- Income should be understood in its commercial sense – Computing total income of assessee equal to total receipts for year was not in accordance with commercial prudence – Addition deleted. [ S. 12AA ]
S. 143(1)(a) : Assessment – Intimation – Income from house property or income from business – Mistake of Auditor – Reported clause 16(d) of Form No. 3CD – Addition is not justified .[ S. 22,28(i) Form No 3CD ]
S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Make available – Sales services – Not assessable as technical services – DTAA – India-Singapore [S.90 , Art.12(4)(b) ]
S. 90: Double taxation relief- Capital gains- Shares – Compulsorily Convertible Preference Shares – Exempt from tax – DTAA – India- Mauritius [ S. 45 , Art. 13(3A), 13(3B) ]
S. 80G: Donation- Not started activities – Application is filed beyond six months -Rejection of application is not valid .[ S.80G(5) Form 10AB ]
S. 12AA : Procedure for registration –Trust or institution- Objects of the Trust should be charitable in nature and its activities were genuine- The Commissioner (E) was directed to grant registration to trust from the date of application. [ S. 2(15) , 12A ]
S.10(35): Units of mutual fund – Dividend Mutual Funds – Dividend income earned cannot be subject to tax .[S. 115BBDA, 154 ]