Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
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Under secondment arrangements, taxability of reimbursement of expatriate salary costs and any obligation to deduct tax at source depends on the terms and substance of the secondment agreements, the actual nature of services, and the employment conditions in India. ITAT noted that the issue could not be resolved by precedent alone because the relevant agreements were not examined by the assessee, the AO, or the CIT(A). The matter was therefore restored to the AO for fresh adjudication after calling for the complete agreements and related material, and after considering whether income accrued to the foreign entity in India and whether disallowance under s. 40(a)(i) arose.
Under secondment arrangements, taxability of reimbursement of expatriate salary costs and any obligation to deduct tax at source depends on the terms and substance of the secondment agreements, the actual nature of services, and the employment conditions in India. ITAT noted that the issue could not be resolved by precedent alone because the relevant agreements were not examined by the assessee, the AO, or the CIT(A). The matter was therefore restored to the AO for fresh adjudication after calling for the complete agreements and related material, and after considering whether income accrued to the foreign entity in India and whether disallowance under s. 40(a)(i) arose.
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