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Retrospective amendment - curtailment of the sales tax incentives by way of deferral Ė constitutional validity - impact on completed assessment - The amended provisions cannot be invoked and applied in the present factual controversy. - HC    *    Demand of interest and penalty - bonafide belief - Nature of works contract civil contract or construction contract - appellant paid the tax on the basis of 12% later on - The authorities below have committed an error of law and when the tax imposed has already been paid by the appellant, the penalty and interest is therefore not required to be liable to be paid by the appellant. - HC    *    Addition u/s 40A(2)(a) r.w.s 69C - whether the appellant has substantiated the plea that the visits made to foreign countries were for promotion of business? - appellant did not satisfy the requirements for claiming deductions, disallowance has to consequently follow. - HC    *    Donation paid to political party - deduction u/s 80GGC - All the documents indicate that JOGO party is unrecognized registered political party u/s 29A of the Representation of People Act, 1951. The contribution return in form No. 24A filed with Election Commission of India, indicate the name and address of donor details - Deduction allowed - Tri    *    Eligible to claim deduction under sec. 54F - For availing deduction under sec. 54F of the Act, the property though shown as residential on the record of the municipality but the test will be actual user of the premises by the assessee during the relevant period. - Tri    *    Cenvat credit on water treatment plant    *    Employees sent on deputation to subsidiary/ associate companies (Service Tax)    *    CIT u/s 263 has simply directed the AO, without satisfying himself, to verify whether the bifurcation made by assessee was with a view to reduce tax or not. No infirmity for offering the tax on sale of brands as LTCG. There is no merit in CITís observation for treating the same as business income. - Tri    *    Duty drawback    *    MEIS procedure for export    *    Subcontract Manufacturing by 100% EOU for a Main contractor (Outside India) who is in contract with an Indian Brand Owner for supply of Ready Made garments    *    CENVAT CREDIT    *    After GST - Machinery booking on commission    *    New Issue / query = Export against the INR Purchase Order    *    Where supply of goods without transfer to title has to be treated as service, whether on importation of such goods i.e. deemed services, customs duty and GST would be levied simultaneously?    *    First stage dealer    *    determination of assessable value for job work transaction    *    Cabinet approves Agreement and the Protocol between India and Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion    *    Appointment of Common Adjudicating Authority by DGRI    *    Boarding and Rummaging of vessels, aircrafts and vehicles
DTAA
Home Acts & Rules DTAA Old_Provisions Finland (Old - Effective upto 31-3-2011)

Finland (Old - Effective upto 31-3-2011)

 
Article 1 : Personal scope
Article 2 : Taxes covered
Article 3 : General definitions
Article 4 : Fiscal domicile
Article 5 : Permanent establishment
Article 6 : Income from immovable property
Article 7 : Business profits
Article 8 : Air transport
Article 9 : Shipping
Article 10 : Associated enterprises
Article 11 : Dividends
Article 12 : Interest
Article 13 : Royalties and fees for technical services
Article 14 : Capital gains
Article 15 : Independent personal services
Article 16 : Dependent personal services
Article 17 : Directors fees
Article 18 : Artistes and athletes
Article 19 : Pensions and social security payments
Article 20 : Government service
Article 21 : Students and apprentices
Article 22 : Other income
Article 23 : Capital
Article 24 : Elimination of double taxation
Article 25 : Non-discrimination
Article 26 : Mutual agreement procedure
Article 27 : Exchange of information
Article 28 : Diplomatic agents and consular officers
Article 29 : Entry into force
Article 30 : Termination
 
 
 
 
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