Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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