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)

Yards. Aqua Development Ltd

Editorial: Choice of the Delhi Highest Courtroom inside CIT v. Meters. Meters. Aqua Tech Ltd (2015) 376 ITR 498 (Delhi)(HC) and CIT v. Meters. Meters. Aqua Development Ltd (2016) 386 ITR 441 (Delhi) (HC), corrected.

S. 44: Insurance policies organization – Assessee, a 3rd party administrator / agent (TPA) out-of insurance vendors and you can insurance company differ organizations around IRDA legislation – Assessee becoming a TPA did not slip within purview from organization of insurance carrier

Stored of the Large Judge, that the Assessee getting a third party manager / broker (TPA) of insurance providers are influenced by arrangements of the Insurance coverage Regulatory and Creativity Power of Asia (‘IRDA‘). IRDA rules obviously differentiates TPA in addition to insurance company and hence both are more entities lower than IRDA laws. Zero.593 off 2013, dt. 21-10-2020) (AY. 2009-10)

S. forty-five : Money gains – Deal out-of purchases from offers simple in order to taxation – Reason away from tax prevention maybe not associated so long as operate in this the fresh new frame-work off legislation – Exchange not that have intent in order to avid taxation – DTAA-India-Mauritius [S. 245R(2), Ways thirteen(4)]

(mehr …)