Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the assessee company nor having any authority to conclude contracts, it has neither concluded any contracts nor has it secured any orders for the assessee company in India, thus, cannot be regarded as agency PE - not taxable in India
Income accrued in India - PE - India-USA DTAA - taxability of ‘Instructor Fee’ earned from ‘GIA India Lab’ - GIA India Lab is not acting in India on behalf of the assessee company nor having any authority to conclude contracts, it has neither concluded any contracts nor has it secured any orders for the assessee company in India, thus, cannot be regarded as agency PE - not taxable in India
Note: It is a system-generated summary and is for quick reference only.