Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
Applicability of Article 7 of the Double Taxation Avoidance Agreement (DTAA) between India and the United Arab Emirates regarding the taxation of profits attributed to a Permanent Establishment (PE) in India. The key points are: Income of a non-resident is taxable in India based on the principles of income accruing or arising, while global income of a resident is subject to taxation. Article 7 stipulates that only profits attributable to the PE are taxable in the source state, not the overall profits of the enterprise. The taxability of a PE's income is independent of the global profitability of the enterprise. The source state's right to tax a PE cannot be contingent upon the entity's overall income or loss. The decision clarifies that Article 7 does not restrict the source state's right to allocate income to the PE based on global income or loss of the cross-border entity.
Applicability of Article 7 of the Double Taxation Avoidance Agreement (DTAA) between India and the United Arab Emirates regarding the taxation of profits attributed to a Permanent Establishment (PE) in India. The key points are: Income of a non-resident is taxable in India based on the principles of income accruing or arising, while global income of a resident is subject to taxation. Article 7 stipulates that only profits attributable to the PE are taxable in the source state, not the overall profits of the enterprise. The taxability of a PE's income is independent of the global profitability of the enterprise. The source state's right to tax a PE cannot be contingent upon the entity's overall income or loss. The decision clarifies that Article 7 does not restrict the source state's right to allocate income to the PE based on global income or loss of the cross-border entity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
