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  • Corporate Tax
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NR rendering support services to Indian affiliate via seconded employees constituted its service PE in India

Tenet Tax Daily April 15 2015

Posted onon April 15, 2015
  • Corporate Tax
  • International Tax

AMP exp. incurred on brand promotion of foreign AE would attract TP provisions

Tenet Tax Daily April 14 2015

Posted onon April 15, 2015
  • Corporate Tax

Capital gain accrues on relinquishment of rights in land to developer to get constructed area

Tenet Tax Daily April 13 2015

Posted onon April 15, 2015
  • Corporate Tax

Case restored to AO as additional evidence filed before ITAT was relevant to decide allowability of impugned exp.

Tenet Tax Daily April 11 2015

Posted onon April 15, 2015
  • Corporate Tax

Date of allotment of land would be its date of acquisition and not the date of sale deed to compute capital gains

Tenet Tax Daily April 10 2015

Posted onon April 15, 2015
  • Corporate Tax

Sec. 234C interest to be computed considering date of presentation of cheque of tax payments & not its clearing date

Tenet Tax Daily April 09 2015

Posted onon April 15, 2015
  • Corporate Tax

Allotment of flats under self financing scheme of DDA has to be deemed as construction of house for sec. 54F relief

Tenet Tax Daily April 08 2015

Posted onon April 8, 2015
  • Corporate Tax
  • International Tax

Sum paid on testing of ultrasonic meter wasn’t FTS as it didn’t satisfy make available clause of India-USA DTAA

Tenet Tax Daily April 07 2015

Posted onon April 8, 2015
  • Corporate Tax
  • International Tax

Co. outsourcing major portion of its business to third party couldn’t be taken as comparable for ITES provider

Tenet Tax Daily April 06 2015

Posted onon April 8, 2015
  • Corporate Tax
  • International Tax

Even prior to 2013 India-UK protocol benefit of DTAA was allowed to fiscally transparent firm established in UK

Tenet Tax Daily April 04 2015

Posted onon April 8, 2015
  • Corporate Tax
  • International Tax

Sum paid to NR for support services utilized in overseas contract isn’t liable to TDS

Tenet Tax Daily April 03 2015

Posted onon April 8, 2015
  • Corporate Tax

Cost of production of abandoned TV serial was allowable as business exp. to its producer

Tenet Tax Daily April 02 2015

Posted onon April 2, 2015
  • Corporate Tax

Sec. 54: Booking of unconstructed flat in housing project to be deemed as investment for construction of house

Tenet Tax Daily April 01 2015

Posted onon April 2, 2015
  • Corporate Tax

No reassessment after 4 years to disallow sums paid to NR if assessee had already disclosed all material facts

Tenet Tax Daily March 31 2015

Posted onon March 31, 2015
  • Corporate Tax
  • International Tax

ALP of advertisement exp. reimbursed to foreign AE couldn’t be taken at nil if it was incurred for Indian affiliate

Tenet Tax Daily March 30 2015

Posted onon March 31, 2015
  • Corporate Tax

Security deposit received from lessee isn’t deductible as ‘debt owed’ for computation of net wealth

Tenet Tax Daily March 28 2015

Posted onon March 31, 2015
  • Corporate Tax

Assessment order was invalid as it was issued on basis of time barred notice under sec. 143(2)

Tenet Tax Daily March 27 2015

Posted onon March 27, 2015
  • Corporate Tax
  • International Tax

Commission paid to foreign agent for securing sales order won’t fall within the ambit of ‘FTS’; not liable to TDS

Tenet Tax Daily March 26 2015

Posted onon March 27, 2015

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