Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
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Accrual of income in India - PE in India or not? - UK DTAA - Taxability of receipts from offshore supply on presumptive basis u/s 44BB - Dispute Resolution Panel (DRP) upheld applicability of section 44BB without addressing PE issue - Tribunal considered submissions and material on record, noting assessee's absence of presence for onshore activities and referring to previous decision in assessee's favor for A.Y. 2020-21 - Tribunal ruled in favor of the assessee, holding that section 44BB cannot be invoked to tax offshore supply receipts on a presumptive basis in absence of established PE.
Accrual of income in India - PE in India or not? - UK DTAA - Taxability of receipts from offshore supply on presumptive basis u/s 44BB - Dispute Resolution Panel (DRP) upheld applicability of section 44BB without addressing PE issue - Tribunal considered submissions and material on record, noting assessee's absence of presence for onshore activities and referring to previous decision in assessee's favor for A.Y. 2020-21 - Tribunal ruled in favor of the assessee, holding that section 44BB cannot be invoked to tax offshore supply receipts on a presumptive basis in absence of established PE.
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