Interactive flat panels meeting automatic data processing conditions are distinguished from monitors, while later classification clarifications apply ...
Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Income accrued in India - PE in India - attributing profits to the P.E - Computation made by the A.O. in his assessment order is incorrect as the AO has not allowed the payments made by the Appellant to NSN India for the services rendered by NSN India as a deduction from the profit attributable to the alleged PE. If the said payments are allowed as a deduction from the gross profit figures taken by the A.O., then again the resultant figure would be losses. Consequently, even if the method of attribution adopted by the A.O. is considered to be correct, in any event, there would be no profit/income attributable to the PE. - AT
Income accrued in India - PE in India - attributing profits to the P.E - Computation made by the A.O. in his assessment order is incorrect as the AO has not allowed the payments made by the Appellant to NSN India for the services rendered by NSN India as a deduction from the profit attributable to the alleged PE. If the said payments are allowed as a deduction from the gross profit figures taken by the A.O., then again the resultant figure would be losses. Consequently, even if the method of attribution adopted by the A.O. is considered to be correct, in any event, there would be no profit/income attributable to the PE. - AT
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