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...
Ad hoc disallowance of livestock purchases was unjustified where the assessing officer failed to identify missing documents or defects in the banking records, supplier confirmations and purchase details, and made no meaningful inquiry beyond issuing supplier notices. Computer-generated invoices lacking GST particulars did not establish bogus purchases because live bovine animals were GST-exempt and suppliers were not required to register. Thumb impressions on cash-purchase vouchers, without adverse material, likewise did not disprove genuineness. The disallowance treated as business income was deleted.
Ad hoc disallowance of livestock purchases was unjustified where the assessing officer failed to identify missing documents or defects in the banking records, supplier confirmations and purchase details, and made no meaningful inquiry beyond issuing supplier notices. Computer-generated invoices lacking GST particulars did not establish bogus purchases because live bovine animals were GST-exempt and suppliers were not required to register. Thumb impressions on cash-purchase vouchers, without adverse material, likewise did not disprove genuineness. The disallowance treated as business income was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
