Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Permanent establishment requirements under Article 5 of the India-US DTAA were not met because the Revenue did not establish that the associated enterprise's project office was available to the assessee or that it habitually concluded contracts, maintained stock, or secured orders for it. No fixed place PE or dependent agent PE existed, so no profit attribution arose. Separate offshore supply and repair agreements were supported by the bid terms and contractual arrangements; supplies, repairs and transfer of title occurred outside India. The allegation of artificial contract splitting lacked support. Accordingly, offshore supply, repair and refurbishment receipts were not taxable in India, and the assessment order was set aside.
Permanent establishment requirements under Article 5 of the India-US DTAA were not met because the Revenue did not establish that the associated enterprise's project office was available to the assessee or that it habitually concluded contracts, maintained stock, or secured orders for it. No fixed place PE or dependent agent PE existed, so no profit attribution arose. Separate offshore supply and repair agreements were supported by the bid terms and contractual arrangements; supplies, repairs and transfer of title occurred outside India. The allegation of artificial contract splitting lacked support. Accordingly, offshore supply, repair and refurbishment receipts were not taxable in India, and the assessment order was set aside.
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