Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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.
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