Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Assessment against deceased sole proprietor requires proceedings against the legal representative, rendering prior assessment and appellate orders inv...
Residential waste collection classification under SAC 999423 defeats composite-supply exemption where facilitating goods are not transferred to the lo...
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.
Note: It is a system-generated summary and is for quick reference only.
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