Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Transfer pricing benchmarking and receivables adjustments remanded: segmental financials need proper scrutiny, and foreign-currency interest must trac...
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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