IT – Indo-US Treaty : Persons deputed by an American co. to an Indian co. cannot be considered as its PE in India when services….[ITAT-Mum.]
IT –Indo-German Treaty : Payment made for purchase of software cannot be treated either as interest or royalty or even as technical services
A mere making of claim, which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars regarding income of the assessee
Reopening of an assessment on mere change of opinion without any tangible material is unsustainable
Assets of a company in liquidation cannot be disposed of at the mere pleasure of the company
By virtue of Article 13.4 of India–Mauritius DTAA, capital gain tax is not liable to be charged in India in respect of transfer of shares by a Mauritian company held in an Indian company to another Mauritian company
Indo-Canada Treaty: A special provision in the Income-tax Act cannot be pressed into service to deny the benefit which is otherwise due to FII under the tax treaty provisions notwithstanding their conflict with the domestic law of income tax
Tuesday, March 23, 2010
Income earned by a co-operative society from interest on FDRs / Saving balances with commercial banks qualifies for exemption u/s 80P(2)(a)(i)
Section 143(2)(ii) clearly stipulates service of notice and not issuance of notice. For details view www.taxmann.com
Provisions of section 56(2)(v) applied only to gift on or after 1-9-2004. Source: www.taxmann.com
