Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
