ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
International cargo transhipment through Indian ports continues with Customs-controlled storage, re-export safeguards, and coordinated multi-station m...
Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential treatment of the assessee's receipts by the department. While the receipts from the sale of plant and equipment were subjected to taxation, other receipts were offered as Fees for Technical Services (FTS) under the India-Germany Double Taxation Avoidance Agreement (DTAA). The Tribunal found this inconsistency unjustified, especially considering the lack of valid reasoning provided by the department to establish the existence of a Permanent Establishment (PE) in India.
Taxability in India - amount received by the assessee from offshore supplies of plants and equipments - PE in India or not? - The Tribunal questioned the differential treatment of the assessee's receipts by the department. While the receipts from the sale of plant and equipment were subjected to taxation, other receipts were offered as Fees for Technical Services (FTS) under the India-Germany Double Taxation Avoidance Agreement (DTAA). The Tribunal found this inconsistency unjustified, especially considering the lack of valid reasoning provided by the department to establish the existence of a Permanent Establishment (PE) in India.
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