Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
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...
The assessee, a US LLC engaged in providing domain name registration, web hosting, web designing, SSL certification services, etc., was held to be a tax resident of the USA and entitled to the benefits of the India-USA DTAA. The Tribunal recognized the assessee LLC, having two partners who are US residents filing a US partnership return, as a resident of the USA for taxation purposes. Regarding the taxability of income from services provided, the Tribunal remanded the issue to the AO to examine the applicability of the DTAA provisions vis-`a-vis the various services rendered by the assessee and the income received thereon, after providing an adequate opportunity of being heard.
The assessee, a US LLC engaged in providing domain name registration, web hosting, web designing, SSL certification services, etc., was held to be a tax resident of the USA and entitled to the benefits of the India-USA DTAA. The Tribunal recognized the assessee LLC, having two partners who are US residents filing a US partnership return, as a resident of the USA for taxation purposes. Regarding the taxability of income from services provided, the Tribunal remanded the issue to the AO to examine the applicability of the DTAA provisions vis-`a-vis the various services rendered by the assessee and the income received thereon, after providing an adequate opportunity of being heard.
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