Gujarat High Court held that provisions of Section 13 of the Income Tax Act can be invoked only at the time of assessment and not at the time of grant of registration under Section 12A of the Act.
Following SC's E-Funds ruling, Delhi ITAT confirmed Concentrix US has no PE in India. The Tribunal also held that IPLC/link charges are non-taxable reimbursements, not 'royalty' under Article 12 of ...