Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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