Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Offshore principal-to-principal sales of cars were held not taxable in India because the Indian distributor was an independent entity and did not constitute either a fixed place permanent establishment or a dependent agent permanent establishment under Article 5 of the India-Germany DTAA. The cars were manufactured outside India and sold outside India, and the Revenue could not show any distinguishing factual or legal feature from earlier co-ordinate Bench rulings in the assessee's own case. As no PE existed, the addition treating the business income as taxable in India was unsustainable, and attribution and related computation did not survive; consequential relief followed.
Offshore principal-to-principal sales of cars were held not taxable in India because the Indian distributor was an independent entity and did not constitute either a fixed place permanent establishment or a dependent agent permanent establishment under Article 5 of the India-Germany DTAA. The cars were manufactured outside India and sold outside India, and the Revenue could not show any distinguishing factual or legal feature from earlier co-ordinate Bench rulings in the assessee's own case. As no PE existed, the addition treating the business income as taxable in India was unsustainable, and attribution and related computation did not survive; consequential relief followed.
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