Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
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Article 5(2)(l) of the India-USA DTAA requires cumulative satisfaction of services being furnished or performed in India through employees or other personnel for the prescribed period before a service permanent establishment arises. Cost-to-cost reimbursements of expenditure initially incurred and later cross-charged without mark-up do not establish such a presence where the activity is performed remotely and the non-resident's employees or personnel have no physical presence in India. In those circumstances, no service permanent establishment or taxable income in India arises from the reimbursements.
Article 5(2)(l) of the India-USA DTAA requires cumulative satisfaction of services being furnished or performed in India through employees or other personnel for the prescribed period before a service permanent establishment arises. Cost-to-cost reimbursements of expenditure initially incurred and later cross-charged without mark-up do not establish such a presence where the activity is performed remotely and the non-resident's employees or personnel have no physical presence in India. In those circumstances, no service permanent establishment or taxable income in India arises from the reimbursements.
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