Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The Authority for Advance Rulings (AAR) examined whether a Fixed Place Permanent Establishment (PE) or a Dependent Agent PE (DAPE) existed in India for the assessee. The Assessing Officer (AO) found that the Indian subsidiary, Krones India Pvt. Ltd. (KIPL), was adequately compensated at arm's length for completing agreements involving installation, commissioning, and after-sales services. Since no further attribution would arise, these findings were insignificant. Regarding the Pepsico Jainpur project, the AO found that KIPL was awarded the work, and the assessee only affected certain supplies. Applying the DAPE principles from Progress Rail Locomotive Inc., the High Court held that the appeal failed to raise any substantial questions of law.
The Authority for Advance Rulings (AAR) examined whether a Fixed Place Permanent Establishment (PE) or a Dependent Agent PE (DAPE) existed in India for the assessee. The Assessing Officer (AO) found that the Indian subsidiary, Krones India Pvt. Ltd. (KIPL), was adequately compensated at arm's length for completing agreements involving installation, commissioning, and after-sales services. Since no further attribution would arise, these findings were insignificant. Regarding the Pepsico Jainpur project, the AO found that KIPL was awarded the work, and the assessee only affected certain supplies. Applying the DAPE principles from Progress Rail Locomotive Inc., the High Court held that the appeal failed to raise any substantial questions of law.
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