Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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DRP directions bind the final assessment order, but a patent computation omission may be rectified within the statutory period where the directions were reproduced but not implemented. An Indian subsidiary does not create a permanent establishment merely on facts previously found insufficient to establish one, so no business-profit attribution follows on that basis. Third-party cost reimbursements received without mark-up are not fees for included services unless the services are technical or consultancy services and make available the requisite technical knowledge or know-how under the India-USA DTAA. Corporate guarantee commission must be benchmarked on the taxpayer's facts; a fixed formula without examining the taxpayer's benchmarking is inappropriate.
DRP directions bind the final assessment order, but a patent computation omission may be rectified within the statutory period where the directions were reproduced but not implemented. An Indian subsidiary does not create a permanent establishment merely on facts previously found insufficient to establish one, so no business-profit attribution follows on that basis. Third-party cost reimbursements received without mark-up are not fees for included services unless the services are technical or consultancy services and make available the requisite technical knowledge or know-how under the India-USA DTAA. Corporate guarantee commission must be benchmarked on the taxpayer's facts; a fixed formula without examining the taxpayer's benchmarking is inappropriate.
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