Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Salary reimbursement for seconded employees was held not to be fee for technical services where, during secondment, the employees were released from the foreign entity, worked solely for the Indian company, and remained under its exclusive control, direction and supervision. The Indian company bore the salary cost, could evaluate, discipline, suspend and terminate the secondees, and tax was deducted in India on the salary payments. A small administrative disbursement made in Japan and reimbursed without markup did not change the character of the payment. The Tribunal therefore deleted the FTS addition and distinguished Centrica India Offshore on the facts; the same conclusion applied to the connected appeals.
Salary reimbursement for seconded employees was held not to be fee for technical services where, during secondment, the employees were released from the foreign entity, worked solely for the Indian company, and remained under its exclusive control, direction and supervision. The Indian company bore the salary cost, could evaluate, discipline, suspend and terminate the secondees, and tax was deducted in India on the salary payments. A small administrative disbursement made in Japan and reimbursed without markup did not change the character of the payment. The Tribunal therefore deleted the FTS addition and distinguished Centrica India Offshore on the facts; the same conclusion applied to the connected appeals.
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