Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
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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