Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Strict construction of customs exemptions denied concession for brake components, while limitation restricted differential duty to timely Bills of Ent...
Way Leave Permissions cannot be retrospectively revived through insolvency plans, and affected infrastructure holders require safety review and hearin...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
