Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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Under the retrospective amendment to sections 144C, 153 and 153B, the limitation periods under sections 153 and 153B apply only until the draft assessment order is forwarded. Thereafter, the Dispute Resolution Panel process and the Assessing Officer's finalisation operate under separate timelines, so a limitation objection to the final assessment order does not succeed. Buying agency services involving vendor identification, order placement, quality checks, logistics coordination and related procurement support are characterised as commercial agency functions rather than managerial, technical or consultancy services under Article 12(4) of the India-Switzerland DTAA. The resulting receipts remain business income and, absent a permanent establishment in India, are not taxable in India; the fees-for-technical-services addition is deleted, with interest consequential.
Under the retrospective amendment to sections 144C, 153 and 153B, the limitation periods under sections 153 and 153B apply only until the draft assessment order is forwarded. Thereafter, the Dispute Resolution Panel process and the Assessing Officer's finalisation operate under separate timelines, so a limitation objection to the final assessment order does not succeed. Buying agency services involving vendor identification, order placement, quality checks, logistics coordination and related procurement support are characterised as commercial agency functions rather than managerial, technical or consultancy services under Article 12(4) of the India-Switzerland DTAA. The resulting receipts remain business income and, absent a permanent establishment in India, are not taxable in India; the fees-for-technical-services addition is deleted, with interest consequential.
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