Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
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.
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