Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Assessee's expat salary expenses reimbursed to SanDisk India not taxable as FTS. No agency PE of assessee in India through SanDisk India for relevant year as no transaction between them. Revenue failed to establish SanDisk India acted on behalf of assessee to constitute dependent agency PE under tax treaty. No interrelated transaction brought on record between assessee and SanDisk India as associated enterprises for relevant year. No attribution of SanDisk India's profits to assessee permissible. Decided in assessee's favor.
Assessee's expat salary expenses reimbursed to SanDisk India not taxable as FTS. No agency PE of assessee in India through SanDisk India for relevant year as no transaction between them. Revenue failed to establish SanDisk India acted on behalf of assessee to constitute dependent agency PE under tax treaty. No interrelated transaction brought on record between assessee and SanDisk India as associated enterprises for relevant year. No attribution of SanDisk India's profits to assessee permissible. Decided in assessee's favor.
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