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...
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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.
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