Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Denial of tax treaty benefit due to lack of commercial substance in Singapore - Benefit of DTAA - In any event, the ld. AO in all fairness ought to have accepted the assessment orders of Singapore Tax Authorities which goes to prove that the Assessee is a tax resident of Singapore and is independently carrying on its business activities in Singapore. All these documents and behavior of the Assessee collectively go to prove that affairs of the Assessee company were not controlled from outside Singapore. - AT
Denial of tax treaty benefit due to lack of commercial substance in Singapore - Benefit of DTAA - In any event, the ld. AO in all fairness ought to have accepted the assessment orders of Singapore Tax Authorities which goes to prove that the Assessee is a tax resident of Singapore and is independently carrying on its business activities in Singapore. All these documents and behavior of the Assessee collectively go to prove that affairs of the Assessee company were not controlled from outside Singapore. - AT
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