Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The Income Tax Appellate Tribunal (ITAT) held that SanDisk India did not constitute a Dependent Agency Permanent Establishment (DAPE) of the assessee foreign company, SanDisk Ireland. Consequently, the assessee's income is not taxable in India. Regarding the reimbursement of salary expenses for seconded employees, the ITAT remitted the issue of whether it qualifies as Fees for Technical Services (FTS) to the Assessing Officer for fresh adjudication, as the relevant agreement was not available to determine if the services were for an indefinite period.
The Income Tax Appellate Tribunal (ITAT) held that SanDisk India did not constitute a Dependent Agency Permanent Establishment (DAPE) of the assessee foreign company, SanDisk Ireland. Consequently, the assessee's income is not taxable in India. Regarding the reimbursement of salary expenses for seconded employees, the ITAT remitted the issue of whether it qualifies as Fees for Technical Services (FTS) to the Assessing Officer for fresh adjudication, as the relevant agreement was not available to determine if the services were for an indefinite period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
