Tenet Tax Daily July 27 2013
Sec. 54F exemption allowed on mere investment – completion of contruction within stipulated period not essential
Payment received by foreign company from Indian franchisee for international marketing activities is not “royalty” under Article 12(4) of DTAA even if its on the basis of % of gross revenue
Tenet Tax Daily July 26 2013
Revenue allocated to German HO by Indian BO not taxable in India as India-Germany DTAA allows “fee splitting arrangement”
Tenet Tax Daily July 25 2013
Mere submitting an incorrect claim without malafide intention doesn’t attract concealment penalty
Tenet Tax Daily July 24 2013
Payments for launching and tracking of satellite aren’t FTS as no technology is made available to assessee
Tenet Tax Daily July 23 2013
Payment of consultancy fees to carry on business more efficiently and profitably is a revenue expenditure
Tenet Tax Daily July 22 2013
AAR can only determine tax liability of applicant and not any of its affiliate or AOP
Tenet Tax Daily July 20 2013
AAR can only determine tax liability of applicant and not any of its affiliate or AOP
DRP should pass a speaking order considering all objections raised by assessee
Tenet Tax Daily July 18 2013
Payment for downloading licensed software is payment of ‘royalty’ subject to withholding tax
Tenet Tax Daily July 17 2013
No concealment penalty u/s 271(1)(c) on mere disallowance of a claim if full details were disclosed in return
Tenet Tax Daily July 16 2013
Subsidiary company is not a ‘related person’ for sec. 40A(2)
Tenet Tax Daily July 15 2013
Entities incurring losses in odd circumstances excluded from list of comparables for TP study
Tenet Tax Daily July 13 2013
Assessee not required to establish irrecoverability of a debt before writing it off to claim bad debt deduction.
Tenet Tax Daily July 12 2013
Ahmedabad HC – Submission of audited accounts doesnot mean AO cannot order for special audit
Tenet Tax Daily July 11 2013
Pre-payment charges for closure of housing loan eligible for Section 24 deductions.
Tenet Tax Daily July 09 2013