Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
