Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
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...
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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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