Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
Original works exemption excludes standalone boulder transportation, leaving subcontracted railway-project transport services subject to service tax l...
Annual production capacity determinations excluding stenter galleries support refunds for unconstitutional excise levies without an unjust-enrichment ...
Vicarious liability for cheque dishonour requires specific allegations of responsibility and cheque signatory; generic director allegations cannot sus...
IT Resilience Index requires market infrastructure institutions to automate resilience scoring, early warnings, and continuous service-delivery monito...
Income deemed to accrue or arise in India - Attribution of Profit to permanent establishment (PE) in India - The Tribunal observed that while the Assessing Officer attributed 25% of the profit to the PE in India, only one contract was thoroughly examined, neglecting others. The Tribunal found this attribution to be arbitrary and lacking proper analysis. The estimation of profit rate at 10% was deemed unjustified, especially considering the Assessee's evidence of a lower global profit rate. The Tribunal, therefore, directed a de novo adjudication by the Assessing Officer after considering all relevant factors and providing a reasonable opportunity to the Assessee.
Income deemed to accrue or arise in India - Attribution of Profit to permanent establishment (PE) in India - The Tribunal observed that while the Assessing Officer attributed 25% of the profit to the PE in India, only one contract was thoroughly examined, neglecting others. The Tribunal found this attribution to be arbitrary and lacking proper analysis. The estimation of profit rate at 10% was deemed unjustified, especially considering the Assessee's evidence of a lower global profit rate. The Tribunal, therefore, directed a de novo adjudication by the Assessing Officer after considering all relevant factors and providing a reasonable opportunity to the Assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
