[aaykarbhavan] Fw: Pre-Print Highlights of ITR(Trib) from CLI
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From: "info@cliofindia.com" <info@cliofindia.com>
To: newsletter@cli.in
Sent: Saturday, 19 January 2013 7:03 AM
Subject: Pre-Print Highlights of ITR(Trib) from CLI
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ITR'S TRIBUNAL TAX REPORTS (ITR (Trib)) HIGHLIGHTS
APPELLATE TRIBUNAL ORDERS |
F Non-resident : Where property in ships "not effectively connected" with PE in India, profits not assessable in India : ADIT (International Taxation) v. Mediterranean Shipping Co. S.A. (Mumbai) p. 300
F Income : Interest earned from overseas branches chargeable : ADIT (International Taxation) v. Credit Agricole Indosuez (Mumbai) p. 345
F Interest paid in respect of broken period to be set off against interest received in respect of broken period : ADIT (International Taxation) v. Credit Agricole Indosuez (Mumbai) p. 345
F Interest on foreign currency loans allowable on gross interest and not on net interest : ADIT (International Taxation) v. Credit Agricole Indosuez (Mumbai) p. 345
F Interest paid by Indian PE to overseas head office or branches not allowable as deduction : ADIT (International Taxation) v. Credit Agricole Indosuez (Mumbai) p. 345
F Profit from unmatured forward exchange contract taxable : ADIT v. Credit Lyonnais (Mumbai) p. 359
F Where charitable object of trust not changed, cancellation of registration not proper : Krupanidhi Educational Trust v. DIT (Exemption) (Bangalore) p. 373
F Where failure by assessee to provide any evidence on foreign tour expenses of accompanying spouse of directors, expenditure disallowable : Harinagar Sugar Mills Ltd. v. Asst. CIT (Mumbai) p. 383
F Tribunal has no power to review : Smt. V. Kumuda v. Dy. CIT (Hyderabad) p. 396
F Interest on refund of TDS taxable under article 11(2) of DTAA (USA) : Bechtel International Inc. v. Asst. DIT (Mumbai) p. 404
F Club expenses allowable for business expenditure : Jindal Iron and Steel Co. Ltd. v. Dy. CIT (Mumbai) p. 414
F Where ICDs part of business of assessee, loss on investment deductible : Jindal Iron and Steel Co. Ltd. v. Dy. CIT (Mumbai) p. 414
F Life Centenary Celebrations of Sri K. Sadagopachari-Justice Sri S. Ranganathan, Supreme Court of India (Retd.) p. 1
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