Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
On identical facts, the ITAT followed its earlier order and held that the Revenue had failed to establish any permanent establishment in India for the assessee in relation to offshore supply under the ONGC contract. As a result, the offshore supply receipts could not be taxed on a presumptive basis under section 44BB, and the addition was deleted. The Tribunal also noted that the DRP had found the facts unchanged from earlier years; interest and penalty grounds were treated as consequential.
On identical facts, the ITAT followed its earlier order and held that the Revenue had failed to establish any permanent establishment in India for the assessee in relation to offshore supply under the ONGC contract. As a result, the offshore supply receipts could not be taxed on a presumptive basis under section 44BB, and the addition was deleted. The Tribunal also noted that the DRP had found the facts unchanged from earlier years; interest and penalty grounds were treated as consequential.
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