Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
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Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The project sites at Bangaluru and Gurugram cannot be considered to be either installation or supervisory PE of the assessee in India. - The assessee in the year under consideration did not have any PE in India. - AT
Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The project sites at Bangaluru and Gurugram cannot be considered to be either installation or supervisory PE of the assessee in India. - The assessee in the year under consideration did not have any PE in India. - AT
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