Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
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Dependent agent permanent establishment issues are addressed in relation to software licence distribution where the Indian subsidiary's arm's length price was accepted without adjustment. The note reports that, following an earlier ITAT order on materially similar facts and absent contrary higher-forum authority, the business-income attribution based on the alleged dependent agent permanent establishment was deleted. It also addresses refund interest included in a draft assessment order without prior reference in the show-cause notice. As the claimed non-receipt of such interest was unexamined, the matter was remitted for fresh consideration after allowing supporting evidence.
Dependent agent permanent establishment issues are addressed in relation to software licence distribution where the Indian subsidiary's arm's length price was accepted without adjustment. The note reports that, following an earlier ITAT order on materially similar facts and absent contrary higher-forum authority, the business-income attribution based on the alleged dependent agent permanent establishment was deleted. It also addresses refund interest included in a draft assessment order without prior reference in the show-cause notice. As the claimed non-receipt of such interest was unexamined, the matter was remitted for fresh consideration after allowing supporting evidence.
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