Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
Nature of income offered u/s 44BB - PE in India or not - Receipts from leasing/hiring of RIGs - sections 9(1)(vi), 44BB and 44DA apply in different situations. - The fundament error committed by learned DRP is in holding that section 44BB will be applicable only in a case where non-resident has a PE in India. The aforesaid conclusion of learned DRP is based on complete misinterpretation of the provision and goes against the very essence of the provision, which does not put the condition of existence of PE for applicability of the provision. - AT
Nature of income offered u/s 44BB - PE in India or not - Receipts from leasing/hiring of RIGs - sections 9(1)(vi), 44BB and 44DA apply in different situations. - The fundament error committed by learned DRP is in holding that section 44BB will be applicable only in a case where non-resident has a PE in India. The aforesaid conclusion of learned DRP is based on complete misinterpretation of the provision and goes against the very essence of the provision, which does not put the condition of existence of PE for applicability of the provision. - AT
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