Income accrued in India - section 9(1)(i) - Explanation 5 has ...

October 19, 2020

Case Laws Income Tax AT

Income accrued in India - section 9(1)(i) - Explanation 5 has been given retrospective effect and Explanations 6 and 7 have been inserted in furtherance of the object of insertion of Explanation 5, these two explanations cannot be read in isolation, but have to be tagged alongwith Explanation 5 so that both the Explanations have to be given a retrospective effect - AT

View Source

← Previous Next →

Income accrued in India - section 9(1)(i) - Explanation 5 has ...

October 19, 2020

Case Laws Income Tax AT

You may also like:

Interest u/s 234B - The term “assessed tax” has been defined in Explanation-1 of Section 234B (1). As per said Explanation-1 “assessed tax” means the tax on the total...

Levying MAT u/s 115JB - 100% reduction of the profit u/s. 80IB(10) - while computing the book profit u/s. 115JB appellant had reduced it from book profit and claimed...

Income accrued in India - nature of fees for technical services - the provisions of Section 9(1)(i) are not attracted in this case as no income has accrued or arised...

Explanation versus bona finde explanation versus proper disclosure - Penalty under section 271(1)(c) - AT

The case dealt with the taxability of income in India related to royalty receipts and Tax Deducted at Source (TDS) u/s 195. The respondent did not deduct tax on...

Income accrued in India - Royalty u/s.9(1)(vi) - intra-group services fees - Coming to the Indo-Spain DTAA, it is axiomatic that the domestic law has not been linked...

Offshore Supply Contracts were executed and concluded outside India, hence no income deemed to accrue or arise in India as per Section 9(1) and DTAA provisions. Receipts...

MAT - Adjustments to book profit - Disallowance as per the clause (f) to Explanation-1 of Sec. 115JB of the Act independently - there is no mechanism provided under the...

Penalty u/s 271(1)(c) - proof of contravention of provisions provided under explanation 5A to section 271(1)(c) - On reference to the provisions of explanation 5A to...

Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

Determination of residential status of assessee - Relaxation of period of 60 days as per section 6(1)(a) to 182 days when employment is taken outside India as per clause...

Exemption u/s 11 - Accumulation of income - The money referred in Clause (b) (ii) is one accumulated or set apart. Meaning thereby that even if 85% of the income...

Penalty u/s 271(1)(c) was levied on additional income voluntarily offered in the statement recorded u/s 132(4). However, no reference was made to corroborative...

Correctness of erasure of credit already availed by prospective invalidation of eligibility for retention of credit that would subject those services already procured...

Income accrued in India - For the purpose of applying Article 13(5) of the India-Belgium tax treaty two fold conditions are required to be cumulatively satisfied viz....

Quick Updates: