NR/DTAA/MLI – Daily Tax Reporter

1

Commissioner (A) is not empowered to enhance income a new source of income vide 82ITR 9Trib) 176
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It is assessee’s choice to select a method for determining FMV of shares vide 81 ITR (Trib) (SN) 78
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No TP adjustment of trade receivables in case of a debt-free company vide 81ITR (Trib) (SN) 94
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To accord registration as a charitable institution under income tax dominant purpose must be charitable and satisfies the conditions laid down us 2(15) vide 426ITR108 despite having non charitable ancillary objects meant to achieve the dominant purpose
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Transactions with dubious entities is reason enough for case reopening vide 421ITR624

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NR/DTAA/MLI

Eyewash proviso

Apr 11, 2023 CA Gopal Nathani

In a case of transaction of purchase of immovable property from a non resident it is mandatory to deduct tax…

NR/DTAA/MLI

reimbursement of charges is not subject to tax in India

Mar 16, 2023 CA Gopal Nathani

In the matter before Tribunal in (2023] 30 ITR (Trib)-OL 720 (ITAT[Bang] the case involved the question of withholding of…

NR/DTAA/MLI

taxability of receipts from sale of online advertisement space- royalty or EL

Mar 15, 2023 CA Gopal Nathani

The Tribunal in [2023] 30 ITR (Trib)-OL 210 (ITAT[Bang]) gave a green flag chit to Google from royalty tax on revenues…

NR/DTAA/MLI

Retrospective explanations cannot burden tax deductor

Mar 11, 2023 CA Gopal Nathani

Section 9 has been amended from time to time expanding definition of royalty on retrospective basis. Though this may bring…

NR/DTAA/MLI

Problematic situation

Jan 24, 2023 CA Gopal Nathani

In the PepsiCo case @(2023] 30 ITR (Trib)-OL 1 (ITAT[Del]) the subject matter of appeal was essentially covered by the previous…

NR/DTAA/MLI

No TDS on Export commission

Dec 1, 2022 CA Gopal Nathani

Finally in a decision rendered by the Supreme Court in Vedanta ( Bby) and MATRIX CLOTHING PVT. LTD. (Del) case [2022] 448 ITR…

NR/DTAA/MLI

Payments for training not liable to withholding

Nov 18, 2022 CA Gopal Nathani

The Tribunal in [2022] 99 ITR (Trib) 607 (ITAT[Bang]) held that training expenses remain out of the purview of definition of “fee for…

NR/DTAA/MLI

Industrial royalty payments

Nov 3, 2022 CA Gopal Nathani

By the Pune bench decision in 2022] 99 ITR (Trib) 585 (ITAT[Pune])consideration payable for use of the information and communications technology infrastructure set…

NR/DTAA/MLI

lower rate advantage under tax treaty in 197 applications

Aug 9, 2022 CA Gopal Nathani

In making application u/s 197 a non resident can take benefit of DTAA as well as protocols issued for a…

NR/DTAA/MLI

Export Commission to non resident director held chargeable at PE rate

Aug 2, 2022 CA Gopal Nathani

Normally export commission is not chargeable to tax in india unless services are technical or specialised in nature and go…

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