Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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...
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HC determined that the Permanent Establishment (PE) status remained unresolved between jurisdictional tax authorities despite mutual agreement attempts. The MAP determination in 2017 was not properly communicated to the Tribunal, which continued proceedings for Assessment Years 2006-07 and 2008-09 based on incomplete information. The court set aside the existing orders, mandating the Tribunal to comprehensively re-examine the PE issue and tax implications, ensuring a fresh and thorough adjudication of the unresolved taxation matters.
HC determined that the Permanent Establishment (PE) status remained unresolved between jurisdictional tax authorities despite mutual agreement attempts. The MAP determination in 2017 was not properly communicated to the Tribunal, which continued proceedings for Assessment Years 2006-07 and 2008-09 based on incomplete information. The court set aside the existing orders, mandating the Tribunal to comprehensively re-examine the PE issue and tax implications, ensuring a fresh and thorough adjudication of the unresolved taxation matters.
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