Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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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