International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Reopening of assessment u/s 147 - having business connection as well as Permanent Establishment [PE] in India - evidence being sought to be used for initiating fresh enquiry against the assessee does not even pertain to the Assessment Year under consideration. In our considered opinion, whether a PE exists or not is a fact specific issue and is to be decided on year on year basis. - no new tangible material has been brought by the Assessing Officer to justify the reopening - AT
Reopening of assessment u/s 147 - having business connection as well as Permanent Establishment [PE] in India - evidence being sought to be used for initiating fresh enquiry against the assessee does not even pertain to the Assessment Year under consideration. In our considered opinion, whether a PE exists or not is a fact specific issue and is to be decided on year on year basis. - no new tangible material has been brought by the Assessing Officer to justify the reopening - AT
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