Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Permanent Establishment (PE) in India - attribution of profit to the PE - Revenue authorities have not brought any material on record to demonstrate that the activities of DHR India are wholly devoted on behalf of the assessee and as such it does not have any independent status and was not acting in the ordinary course of its business. - there cannot be any PE under Article 5(8) and 5(9) of the Indian – Singapore Tax Treaty. - AT
Permanent Establishment (PE) in India - attribution of profit to the PE - Revenue authorities have not brought any material on record to demonstrate that the activities of DHR India are wholly devoted on behalf of the assessee and as such it does not have any independent status and was not acting in the ordinary course of its business. - there cannot be any PE under Article 5(8) and 5(9) of the Indian – Singapore Tax Treaty. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
