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...
Rejection of liquor-trade book results is justified where proper books, stock registers, sale bills and supporting vouchers are not maintained, and declared profit is materially below comparable industry margins. Profit from liquor trading may then be estimated at 3% of stock put to use. Advertisement-display receipts earned for permitting liquor-product displays in business premises constitute business receipts and may be separately added where they were excluded from turnover used for profit estimation. The rejection of books, profit estimation and separate addition of advertisement-display receipts were sustained, and the appeal was dismissed.
Rejection of liquor-trade book results is justified where proper books, stock registers, sale bills and supporting vouchers are not maintained, and declared profit is materially below comparable industry margins. Profit from liquor trading may then be estimated at 3% of stock put to use. Advertisement-display receipts earned for permitting liquor-product displays in business premises constitute business receipts and may be separately added where they were excluded from turnover used for profit estimation. The rejection of books, profit estimation and separate addition of advertisement-display receipts were sustained, and the appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
