The article in August 2014 issue of Direct Tax Amicus discusses the possible unequal treatment of non-resident on restriction of disallowance to 30% in case of TDS defaults on payments to residents. The clarification on taxation of AIFs having status of non-charitable trusts is covered under “Circulars”. The Ratio Decidendi section includes case law on transfer pricing - advancement of loan for conversion to equity, entity with abnormal profits as a comparable, comparability of entities with brand value and condition as to SSI status to be fulfilled only in the initial year.
August, 2014/Issue-01