Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
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Accrual of income India - Service PE/ virtual service PE in India - computation of threshold date for constitution of service PE - The tribunal concluded that for AY 2020-21, the appellant did not constitute a Service PE in India, as the presence of employees in India did not exceed the 90-day threshold required for constituting a Service PE under the India-Singapore DTAA. For AY 2021-22, since no employees visited India, the appellant could not have constituted a Service PE. Furthermore, the tribunal found no basis for the constitution of a Virtual Service PE as claimed by the AO, given the absence of relevant provisions in the India-Singapore DTAA or substantial evidence to support such a claim.
Accrual of income India - Service PE/ virtual service PE in India - computation of threshold date for constitution of service PE - The tribunal concluded that for AY 2020-21, the appellant did not constitute a Service PE in India, as the presence of employees in India did not exceed the 90-day threshold required for constituting a Service PE under the India-Singapore DTAA. For AY 2021-22, since no employees visited India, the appellant could not have constituted a Service PE. Furthermore, the tribunal found no basis for the constitution of a Virtual Service PE as claimed by the AO, given the absence of relevant provisions in the India-Singapore DTAA or substantial evidence to support such a claim.
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