Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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