Advance-ruling mechanism governs pending GST classification, exemption and taxability disputes, limiting writ review once the specialised forum functi...
Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Arm's-length remuneration of an Indian associated enterprise treated as a dependent agent permanent establishment is discussed as precluding further profit attribution to the non-resident where no transfer-pricing adjustment is made. The notes describe this approach as applying on identical facts to challenges concerning business connection, permanent establishment and attribution of profits. They also address interest on an income-tax refund, stating that it is not effectively connected with the alleged Indian permanent establishment and should be taxed under the interest article of the India-Singapore treaty rather than under normal domestic provisions.
Arm's-length remuneration of an Indian associated enterprise treated as a dependent agent permanent establishment is discussed as precluding further profit attribution to the non-resident where no transfer-pricing adjustment is made. The notes describe this approach as applying on identical facts to challenges concerning business connection, permanent establishment and attribution of profits. They also address interest on an income-tax refund, stating that it is not effectively connected with the alleged Indian permanent establishment and should be taxed under the interest article of the India-Singapore treaty rather than under normal domestic provisions.
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