Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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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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