Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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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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