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...
Reassessment jurisdiction requires recorded reasons to show an independently formed prima facie belief and a rational, live nexus between investigation material and income alleged to have escaped assessment. Information understood as relating to bogus purchases cannot support an assessment of the same amounts as unexplained unsecured loans without transaction-specific application of mind; subsequent findings cannot cure defects in the recorded reasons. For unsecured loans, lender confirmations, banking records, tax documents and affidavits may discharge the initial burden on identity, transaction trail and source. A preceding equivalent bank credit alone does not establish an accommodation entry without verification and cogent rebuttal of the disclosed source.
Reassessment jurisdiction requires recorded reasons to show an independently formed prima facie belief and a rational, live nexus between investigation material and income alleged to have escaped assessment. Information understood as relating to bogus purchases cannot support an assessment of the same amounts as unexplained unsecured loans without transaction-specific application of mind; subsequent findings cannot cure defects in the recorded reasons. For unsecured loans, lender confirmations, banking records, tax documents and affidavits may discharge the initial burden on identity, transaction trail and source. A preceding equivalent bank credit alone does not establish an accommodation entry without verification and cogent rebuttal of the disclosed source.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
