Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Accrual of income in India - PE in India or not? - Agency PE - whether assessee has a business connection in India under Section 9(1)? - The ITAT Delhi ruled in favor of the assessee, finding that the business model post-2005 did not create a Permanent Establishment (PE) or an Agency PE in India for Sabre GLBL Inc., as the operations and agreements post-2005 significantly differed from the earlier model. The Tribunal differentiated the current business operations from those evaluated in the case of Galileo International Inc., where a PE was established due to the presence of an intermediary.
Accrual of income in India - PE in India or not? - Agency PE - whether assessee has a business connection in India under Section 9(1)? - The ITAT Delhi ruled in favor of the assessee, finding that the business model post-2005 did not create a Permanent Establishment (PE) or an Agency PE in India for Sabre GLBL Inc., as the operations and agreements post-2005 significantly differed from the earlier model. The Tribunal differentiated the current business operations from those evaluated in the case of Galileo International Inc., where a PE was established due to the presence of an intermediary.
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