Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
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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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