S.14A: Disallowance of expenditure-Exempt income-No exempt income earned-No disallowance permissible.[R. 8D]
S.14A: Disallowance of expenditure-Exempt income-No exempt income earned-No disallowance permissible.[R. 8D]
S.14A: Disallowance of expenditure-Exempt income-Disallowance under section 14A cannot exceed the exempt income earned during the year-Book profit-Minimum Alternate Tax-Disallowance computed under section 14A read with rule 8D cannot be added while computing book profit under section 115JB. [S. 11JB, R. 8D]
S. 13: Denial of exemption-Trust or institution-Investment restrictions-Exemption cannot be denied on entire income-Disallowance restricted to income from impermissible investment. [S. 11, 12, 13(1)(d)]
S. 11: Property held for charitable purposes-Development of industrial estates constitutes advancement of an object of general public utility-Exemption cannot be denied. [S. 2(15), 12]
S. 10A: Free trade zone-Telecommunication expenses excluded from export turnover must also be excluded from total turnover. S. 10A.
S.10 (1) : Agricultural income-Capital asset-Agricultural land-Land situated within Gram Panchayat-Population below prescribed limit-Rural agricultural land not a capital asset-Estimation-Agricultural operations established by revenue records-Absence of regular books-Fair estimation of income justified.[S. 2(14)(iii),132(4), 153A]
S. 10(1) : Agricultural income-Hybrid seeds-Assessee not owner of agricultural land-Agricultural operations carried out jointly with farmers-Exemption allowable.
S. 9(1)(vi): Income deemed to accrue or arise in India-Royalty-Non-resident-Software licence-Grant of licence to use copyrighted software-No transfer of copyright or copyright rights-Receipts not taxable as royalty under India-Fees for technical services-Non-resident-Software support services-“Make available” condition not satisfied-Receipts not taxable as fees for technical services under India-Netherlands DTAA. [S.9(1)(vii),Art. 12]
S. 9(1)(vi): Income deemed to accrue or arise in India-Royalty-Fees for technical services-Non-resident-Cloud computing services-Receipts not chargeable as royalty or fees for technical services-Not liable to deduct tax at source-DTAA India-USA [S. 9(1)(vii), 195, Art. 12(3), 12(4)]
S. 9(1)(vi): Income deemed to accrue or arise in India-Royalty-Non-resident-Receipts from sale of online advertisement space not taxable as royalty or fees for technical services in absence of Permanent Establishment in India-DTAA-India-Ireland [S. 9(1)(1), 9(1)(vii) 195, Art.7(1)]