Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
The ITAT allowed the taxpayer's appeal, concluding that the Indian affiliate is not a dependent agent PE under Article 5(4) of the India-UK DTAA. The tribunal found the Indian entity to be a separate legal person performing marketing and sales support under its own management and resources, remunerated at arm's length, and lacking authority to bind the nonresident, conclude contracts, maintain stock, or deliver products on the nonresident's behalf. Consequently, the AO's and DRP's attribution of offshore sales profits to a PE in India was annulled and the corresponding income-tax additions were deleted.
The ITAT allowed the taxpayer's appeal, concluding that the Indian affiliate is not a dependent agent PE under Article 5(4) of the India-UK DTAA. The tribunal found the Indian entity to be a separate legal person performing marketing and sales support under its own management and resources, remunerated at arm's length, and lacking authority to bind the nonresident, conclude contracts, maintain stock, or deliver products on the nonresident's behalf. Consequently, the AO's and DRP's attribution of offshore sales profits to a PE in India was annulled and the corresponding income-tax additions were deleted.
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