Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
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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