Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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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