Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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