Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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