Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
ITAT held that two individuals whose travel expenses were reimbursed were employees of the taxpayer's associated enterprise (AE) and constituted an enterprise's personnel, not employees of the taxpayer; consequently their presence in India could not be attributed to the taxpayer for computing stay under Article 5(3)(b) of the DTAA. The Tribunal found the Assessing Officer's inclusion of those days to create a deemed PE was based on conjecture and contrary to the factual record. The additions made by the AO and confirmed by the CIT(A) were deleted, and the appeal was allowed in favour of the taxpayer.
ITAT held that two individuals whose travel expenses were reimbursed were employees of the taxpayer's associated enterprise (AE) and constituted an enterprise's personnel, not employees of the taxpayer; consequently their presence in India could not be attributed to the taxpayer for computing stay under Article 5(3)(b) of the DTAA. The Tribunal found the Assessing Officer's inclusion of those days to create a deemed PE was based on conjecture and contrary to the factual record. The additions made by the AO and confirmed by the CIT(A) were deleted, and the appeal was allowed in favour of the taxpayer.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
