Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
TDS u/s 195 - existence of permanent establishment (PE) - payment made to various non-resident being during the year under consideration for purchase, installation and supervision charges - Assessing officer could not bring any material on record which would establish such a relationship between the independent parties and non-resident vendors wherein habitual/sustained ability to negotiate or secure contracts could be demonstrated. The ld. assessing officer has jumped to the conclusion of existence of permanent establishment due to the involvement of local parties providing auxiliary services. - AT
TDS u/s 195 - existence of permanent establishment (PE) - payment made to various non-resident being during the year under consideration for purchase, installation and supervision charges - Assessing officer could not bring any material on record which would establish such a relationship between the independent parties and non-resident vendors wherein habitual/sustained ability to negotiate or secure contracts could be demonstrated. The ld. assessing officer has jumped to the conclusion of existence of permanent establishment due to the involvement of local parties providing auxiliary services. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
