Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Re-opening of assessment u/s 147 - whether the non-resident entities had Permanent Establishment (“PE”) in India and if the PE existed what would be the income attributable to such alleged PE - in any case, transaction has been found to arm’s length then the entire question of PE becomes academic and there is no merit in the re-assessment proceedings initiated u/s 147 of the Act. - AT
Re-opening of assessment u/s 147 - whether the non-resident entities had Permanent Establishment (“PE”) in India and if the PE existed what would be the income attributable to such alleged PE - in any case, transaction has been found to arm’s length then the entire question of PE becomes academic and there is no merit in the re-assessment proceedings initiated u/s 147 of the Act. - AT
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