Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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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