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...
Income deemed or accrue or arise in India - liaison office - Permanent Establishment (PE) - Revenue though vehemently submitted that liaison office was negotiating price and doing sales activity in India, however, has not brought any sales agreement in support of the claim. It is highly doubtful that sales transaction of such a large scale can be conducted internationally without any written agreement. - the liaison office in Mumbai does not constitute PE of the assessee in India under the provisions of DTAA. - AT
Income deemed or accrue or arise in India - liaison office - Permanent Establishment (PE) - Revenue though vehemently submitted that liaison office was negotiating price and doing sales activity in India, however, has not brought any sales agreement in support of the claim. It is highly doubtful that sales transaction of such a large scale can be conducted internationally without any written agreement. - the liaison office in Mumbai does not constitute PE of the assessee in India under the provisions of DTAA. - AT
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