Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
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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