Authority rules B+G+31 service apartment is commercial building construction, not multi-storey residential for tax classification under RERA definitio...
Resale price method upheld for distribution; assessee's margins accepted and certain transfer-pricing adjustments deleted due to documented reimbursem...
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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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