Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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