Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
