Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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The ITAT held that the Appellant's remuneration for group services performed outside India does not arise in India and thus is not taxable in India under Article 12(5) of the India-Finland DTAA; consequently the Tribunal's prior reasoning in the Appellant's own appeals was affirmed. Separately, the Tribunal determined that guarantee fees charged by the Appellant are passive in nature and, akin to bank guarantee fees, constitute income from other sources rather than business profits, with no permanent establishment attributable; therefore, the Appellant's challenge to the assessment on this point failed. Ground No. 3 was dismissed and the Assessing Officer's order was confirmed.
The ITAT held that the Appellant's remuneration for group services performed outside India does not arise in India and thus is not taxable in India under Article 12(5) of the India-Finland DTAA; consequently the Tribunal's prior reasoning in the Appellant's own appeals was affirmed. Separately, the Tribunal determined that guarantee fees charged by the Appellant are passive in nature and, akin to bank guarantee fees, constitute income from other sources rather than business profits, with no permanent establishment attributable; therefore, the Appellant's challenge to the assessment on this point failed. Ground No. 3 was dismissed and the Assessing Officer's order was confirmed.
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