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...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
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The High Court upheld the validity of reopening assessment u/s 147, finding no jurisdictional error or failure to meet statutory preconditions. Regarding the existence of a fixed place PE and DAPE, the Court relied on its previous binding decision against the appellant, citing principles of consistency and the appellant's failure to establish any fundamental change in facts. The attribution of 35% profits to marketing activities and 75% thereof to the appellant's PE in India by the ITAT was modified, with the HC attributing 26% of total profits to operations carried out by the PE based on its estimate of marketing efforts. The HC found the ITAT's conclusions unexceptionable, dismissing the appellant's challenge.
The High Court upheld the validity of reopening assessment u/s 147, finding no jurisdictional error or failure to meet statutory preconditions. Regarding the existence of a fixed place PE and DAPE, the Court relied on its previous binding decision against the appellant, citing principles of consistency and the appellant's failure to establish any fundamental change in facts. The attribution of 35% profits to marketing activities and 75% thereof to the appellant's PE in India by the ITAT was modified, with the HC attributing 26% of total profits to operations carried out by the PE based on its estimate of marketing efforts. The HC found the ITAT's conclusions unexceptionable, dismissing the appellant's challenge.
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