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CIT (2021) 436 ITR 582/ 204 DTR 337/ 321 CTR 753/ 282 Taxman 281 (SC)

CIT (2021) 436 ITR 582/ 204 DTR 337/ 321 CTR 753/ 282 Taxman 281 (SC)

Meters. Aqua Development Ltd

Editorial: Choice of your Delhi High Legal during the CIT v. Yards. Meters. Aqua Tech Ltd (2015) 376 ITR 498 (Delhi)(HC) and you will CIT v. Yards. Yards. Aqua Technology Ltd (2016) 386 ITR 441 (Delhi) (HC), stopped.

S. 44: Insurance rates organization – Assessee, a 3rd party manager / agent (TPA) regarding insurance providers and you will insurance provider are very different entities less than IRDA rules – Assessee becoming good TPA don’t fall contained in this purview from organization out of insurance company

Held because of the Highest Court, the Assessee getting an authorized officer / representative (TPA) away from insurance agencies is actually governed by terms of the Insurance rates Regulating and Development Authority regarding India (‘IRDA’). IRDA guidelines demonstrably distinguishes TPA and insurance carrier thus both are various other organizations significantly less than IRDA guidelines. Zero.593 away from 2013, dt. 21-10-2020) (AY. 2009-10)

S. forty-five : Financial support progress – Purchase off income out-of offers simple to taxation – Motive regarding tax prevention perhaps not associated so long as operate within this the newest frame work of laws – Deal not having intention in order to avid taxation – DTAA-India-Mauritius [S. 245R(2), Art 13(4)]

Issue accepted of the AAR is actually, “Whether on situations mentioned issues and you can legislation, the main city development toward recommended income from offers away from Betcon Dicknson Asia Individual Limited to the fresh new applicant to help you Betcon Dickinson Holdings Pte. Continuer la lecture de CIT (2021) 436 ITR 582/ 204 DTR 337/ 321 CTR 753/ 282 Taxman 281 (SC)