Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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