Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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