Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Assessment against deceased sole proprietor requires proceedings against the legal representative, rendering prior assessment and appellate orders inv...
Residential waste collection classification under SAC 999423 defeats composite-supply exemption where facilitating goods are not transferred to the lo...
Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
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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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