Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Deduction of rent expenditure was denied because the assessee failed to prove that the new premises were used for business during the relevant AY. Although a rent agreement and an application to shift the excise licence were produced, business use was legally contingent on excise permission and issuance of a new licence, which were granted only in the subsequent AY; without such permission, the assessee could not have shifted operations, and the premises could not be treated as used for business in the year under consideration. The disallowance was therefore sustained and the appeal was dismissed. - HC
Deduction of rent expenditure was denied because the assessee failed to prove that the new premises were used for business during the relevant AY. Although a rent agreement and an application to shift the excise licence were produced, business use was legally contingent on excise permission and issuance of a new licence, which were granted only in the subsequent AY; without such permission, the assessee could not have shifted operations, and the premises could not be treated as used for business in the year under consideration. The disallowance was therefore sustained and the appeal was dismissed. - HC
Note: It is a system-generated summary and is for quick reference only.