Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
TP adjustment in respect of management fee - When the TPO alleges that the assessee has not received any of the above services, it would indicate that the very relationship based on which the assessee company and WeWork Global have been established as AE would be nonexistent. - it is beyond doubt that the assessee is wholly dependent on the use of know-how, patents, copyright, trademark, licences, franchise and other services of We Work Global, for its day to day operation in India. - TPO is not justified in treating the ALP of management fee paid by assessee to WeWork Global at ‘NIL’. - AT
TP adjustment in respect of management fee - When the TPO alleges that the assessee has not received any of the above services, it would indicate that the very relationship based on which the assessee company and WeWork Global have been established as AE would be nonexistent. - it is beyond doubt that the assessee is wholly dependent on the use of know-how, patents, copyright, trademark, licences, franchise and other services of We Work Global, for its day to day operation in India. - TPO is not justified in treating the ALP of management fee paid by assessee to WeWork Global at ‘NIL’. - AT
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TaxTMI 
TaxTMI 
