Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
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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