Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
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Profit attribution to an Indian dependent agency permanent establishment (DAPE) may extend beyond arm's length remuneration where the transfer-pricing analysis fails to capture all functions performed and risks assumed. A Mutual Agreement Procedure resolution binds only the assessment years expressly covered, though its methodology may be applied to other years if facts and functions remain unchanged. Where the DAPE undertakes additional activities beyond those disclosed in the transfer-pricing study, a separate attribution is warranted; profit was restricted to 12% of advertisement revenue rather than the estimated rate. Tax credit for taxes paid by the DAPE requires verification and quantification. Interest is consequential, while a challenge to penalty initiation at assessment stage is premature.
Profit attribution to an Indian dependent agency permanent establishment (DAPE) may extend beyond arm's length remuneration where the transfer-pricing analysis fails to capture all functions performed and risks assumed. A Mutual Agreement Procedure resolution binds only the assessment years expressly covered, though its methodology may be applied to other years if facts and functions remain unchanged. Where the DAPE undertakes additional activities beyond those disclosed in the transfer-pricing study, a separate attribution is warranted; profit was restricted to 12% of advertisement revenue rather than the estimated rate. Tax credit for taxes paid by the DAPE requires verification and quantification. Interest is consequential, while a challenge to penalty initiation at assessment stage is premature.
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