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    September 22, 2026   Case Laws GST
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    Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
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    Compulsorily convertible debentures retain debt character until conversion, while uniform no-interest receivable practices resist transfer-pricing adj...
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    TNMM segmental comparability requires reliable common-expense allocation, while separately reported IT-enabled service segments may remain comparable.
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    Recorded investments under section 69 cannot be treated as unexplained merely because partners' financial capacity is questioned.
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    September 22, 2026   Case Laws Income Tax
    Corroborative evidence for penny-stock additions: alleged undisclosed income and estimated profits failed without substantive proof.
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September 22, 2026   Case Laws GST
Mandatory detention-penalty time limits invalidate delayed orders and require release of security in transit-document discrepancy proceedings.
September 22, 2026   Case Laws Income Tax
Transfer-pricing comparability under TNMM permits rational turnover filters and excludes software-product developers from captive software-services benchmarking.
September 22, 2026   Case Laws Income Tax
Internal comparables under TNMM take priority when audited segmental accounts reliably distinguish AE and non-AE transactions.
September 22, 2026   Case Laws Income Tax
Transitional reassessment savings permit direct reassessment notices after third-party searches conducted during the protected statutory period.
September 22, 2026   Case Laws Income Tax
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengeable.
September 22, 2026   Case Laws GST
Cinematographic-film copyright licensing: GST classification excludes information technology software, preserving regularisation and writ review for jurisdictional error.
September 22, 2026   Case Laws Income Tax
Functional profile determines TNMM over RPM for nil-price product replacement services and arm's-length price recomputation.
September 22, 2026   Case Laws Income Tax
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capital adjustment.
September 22, 2026   Case Laws Income Tax
Compulsorily convertible debentures retain debt character until conversion, while uniform no-interest receivable practices resist transfer-pricing adjustments.
September 22, 2026   Case Laws Income Tax
Demonetization-period cash deposits treated as business receipts cannot be taxed entirely as unexplained money without independent-source evidence.
September 22, 2026   Case Laws Income Tax
TNMM segmental comparability requires reliable common-expense allocation, while separately reported IT-enabled service segments may remain comparable.
September 22, 2026   Case Laws Income Tax
Recorded investments under section 69 cannot be treated as unexplained merely because partners' financial capacity is questioned.
September 22, 2026   Case Laws Income Tax
Belated Form 9A filing may preserve deemed charitable-income application where substantial compliance and sufficient cause are established.
September 22, 2026   Case Laws Income Tax
Corroborative evidence for penny-stock additions: alleged undisclosed income and estimated profits failed without substantive proof.
September 22, 2026   Case Laws Income Tax
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statutory route.
September 22, 2026   Case Laws Customs
Conditional redemption for re-export barred; customs value reassessment and penalties for import misdeclaration remain sustainable.
September 22, 2026   Case Laws Companies Law
Appellate review of interim status quo orders requires prior recourse to the original forum before interference.
September 22, 2026   Case Laws IBC
Interim moratorium exclusion applies retroactively to pending personal-guarantor insolvency applications, while securitisation restraints require written reasons and hearings.
September 22, 2026   Case Laws FEMA
Foreign-exchange seizure powers permit scrutiny of post-commencement payments, while overseas-investment refusals require disclosed, rational reasons.
September 21, 2026   Notifications Labour laws
Provident fund wage ceiling now determines Chapter III coverage and EPF contribution obligations from official publication.

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Home › Highlights › Income Tax › 2014 › July, 2014 › This
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Income Tax

Establishment of PE in India – service PE - Article 5 of Indo-UK ...

India Confirms Permanent Establishment for Assessee Under Article 5 of Indo-UK DTAA.

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Income Tax July 8, 2014 Case Laws AT
Establishment of PE in India – service PE - Article 5 of Indo-UK DTAA – It is thus rightly held that the service PE of the assessee is established in India - AT
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