Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Offshore principal-to-principal sales of CKD kits, raw materials, spare parts and CBU cars may fall outside Indian taxation where contracts are concluded abroad and no further sales activity occurs in India. Mere ownership of an Indian subsidiary does not create a fixed place permanent establishment where the foreign enterprise has no right to use its premises, no place of management there, and conducts no operations in India. An Indian entity acting only as a communication channel, without contract-concluding authority or habitual order securing role, is not a dependent agent. In the absence of a permanent establishment, no profits are attributable to India under the treaty.
Offshore principal-to-principal sales of CKD kits, raw materials, spare parts and CBU cars may fall outside Indian taxation where contracts are concluded abroad and no further sales activity occurs in India. Mere ownership of an Indian subsidiary does not create a fixed place permanent establishment where the foreign enterprise has no right to use its premises, no place of management there, and conducts no operations in India. An Indian entity acting only as a communication channel, without contract-concluding authority or habitual order securing role, is not a dependent agent. In the absence of a permanent establishment, no profits are attributable to India under the treaty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
