Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
Industrial shrimp-feed machinery classification follows its commercial function, placing integrated production plants under the specific industrial fo...
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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