Notification No. 12/97-Customs(N.T.) amendment adds Malur Inland Container Depot in Karnataka to authorized locations for import unloading and export ...
Authority rules B+G+31 service apartment is commercial building construction, not multi-storey residential for tax classification under RERA definitio...
The ITAT upheld the appellate authority's determination that the taxpayer's Mumbai office was a liaison office and did not constitute a permanent establishment, dismissing Revenue's Grounds 1 and 2. The Tribunal confirmed there were no additions in respect of revenues from specified projects after prior directions were given, and found offshore supplies constituted no business connection with the PE in India so as to render fees for technical services taxable under domestic law or the DTAA. The Tribunal further held the DTAA exclusionary clause was inapplicable to interest from an associated enterprise in the absence of a PE, and accordingly dismissed Revenue's Ground 3.
The ITAT upheld the appellate authority's determination that the taxpayer's Mumbai office was a liaison office and did not constitute a permanent establishment, dismissing Revenue's Grounds 1 and 2. The Tribunal confirmed there were no additions in respect of revenues from specified projects after prior directions were given, and found offshore supplies constituted no business connection with the PE in India so as to render fees for technical services taxable under domestic law or the DTAA. The Tribunal further held the DTAA exclusionary clause was inapplicable to interest from an associated enterprise in the absence of a PE, and accordingly dismissed Revenue's Ground 3.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
