Anti-profiteering obligations survive business demerger, complaint withdrawal, and customized supply arrangements where rate-reduction benefits are no...
Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
The ITAT remitted the issue of taxation of service receipts earned by the non-resident appellant under the DTAA provisions to the DRP for fresh consideration. The tribunal directed the appellant to furnish all relevant documents previously withheld, emphasizing the need to determine whether the income qualifies as "Other Income" under Article 22 or "Business Profits" under Article 7, and whether a Permanent Establishment exists in India. The DRP was instructed to re-examine the matter after allowing the appellant an opportunity to be heard and to pass a reasoned order within eight months in accordance with law. Grounds 2 to 2.1 were allowed for statistical purposes, with no conclusive tax liability determined at this stage.
The ITAT remitted the issue of taxation of service receipts earned by the non-resident appellant under the DTAA provisions to the DRP for fresh consideration. The tribunal directed the appellant to furnish all relevant documents previously withheld, emphasizing the need to determine whether the income qualifies as "Other Income" under Article 22 or "Business Profits" under Article 7, and whether a Permanent Establishment exists in India. The DRP was instructed to re-examine the matter after allowing the appellant an opportunity to be heard and to pass a reasoned order within eight months in accordance with law. Grounds 2 to 2.1 were allowed for statistical purposes, with no conclusive tax liability determined at this stage.
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TaxTMI 
TaxTMI 
of 4916 
