Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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...
Fixed place permanent establishment under the India-Thailand DTAA requires cogent evidence that the non-resident enterprise carried on its business through a place at its disposal in India. Survey material showing expatriates working with an Indian group company and receiving remuneration from a Japanese parent did not establish that they acted for the Thailand-based supplier, were deputed by it, or that it had a fixed place of business in India. Associated-enterprise status alone was insufficient to create a permanent establishment. On identical facts, the supplier was treated as having no permanent establishment in India, making the transfer-pricing grounds infructuous.
Fixed place permanent establishment under the India-Thailand DTAA requires cogent evidence that the non-resident enterprise carried on its business through a place at its disposal in India. Survey material showing expatriates working with an Indian group company and receiving remuneration from a Japanese parent did not establish that they acted for the Thailand-based supplier, were deputed by it, or that it had a fixed place of business in India. Associated-enterprise status alone was insufficient to create a permanent establishment. On identical facts, the supplier was treated as having no permanent establishment in India, making the transfer-pricing grounds infructuous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
