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...
Section 270A penalty for misreporting income was deleted where failure to file the original return was unintentional and resulted from severe personal and professional hardship. Salary income had already been subjected to tax deduction at source and was available in departmental records. The assessee disclosed that income in response to reassessment proceedings, and the reassessment accepted the returned income. These facts established reasonable cause and supported immunity from penalty despite non-filing of the original return.
Section 270A penalty for misreporting income was deleted where failure to file the original return was unintentional and resulted from severe personal and professional hardship. Salary income had already been subjected to tax deduction at source and was available in departmental records. The assessee disclosed that income in response to reassessment proceedings, and the reassessment accepted the returned income. These facts established reasonable cause and supported immunity from penalty despite non-filing of the original return.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
