Authentication of paper assessment orders upheld, while qualifying repairs, consumables and vendor advance write-offs remain deductible business claim...
Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
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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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