Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Reassessment following a completed scrutiny assessment was initiated on alleged inflation of Special Economic Zone export profits through non-payment of interest on partners' capital and below-market gold purchases from a sister concern. Relevant transaction particulars had been available during the original assessment, while the amended partnership deed-specifically brought to the Assessing Officer's attention-had rendered the interest-payment clause inoperative. The reopening nevertheless relied on the original deed. Objections concerning the rate and fineness of gold were also not addressed. The reassessment notice and the order rejecting objections were quashed, and the writ petition succeeded.
Reassessment following a completed scrutiny assessment was initiated on alleged inflation of Special Economic Zone export profits through non-payment of interest on partners' capital and below-market gold purchases from a sister concern. Relevant transaction particulars had been available during the original assessment, while the amended partnership deed-specifically brought to the Assessing Officer's attention-had rendered the interest-payment clause inoperative. The reopening nevertheless relied on the original deed. Objections concerning the rate and fineness of gold were also not addressed. The reassessment notice and the order rejecting objections were quashed, and the writ petition succeeded.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
