Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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...
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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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