Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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Whether costs incurred by the Head Office for procurement of software are deductible in computing the business profits of a permanent establishment in India under Article 7(3) of the India-Singapore DTAA: applying precedent (including Supreme Court and ITAT authority), the tribunal found that where the PE was exclusively established to distribute the procured software and the HO made the software available to the PE on a cost-to-cost basis, such procurement costs are bona fide business expenses and therefore allowable as deductions; consequently the PE's business profits were reduced by those costs and the appeal was allowed. - ITAT
Whether costs incurred by the Head Office for procurement of software are deductible in computing the business profits of a permanent establishment in India under Article 7(3) of the India-Singapore DTAA: applying precedent (including Supreme Court and ITAT authority), the tribunal found that where the PE was exclusively established to distribute the procured software and the HO made the software available to the PE on a cost-to-cost basis, such procurement costs are bona fide business expenses and therefore allowable as deductions; consequently the PE's business profits were reduced by those costs and the appeal was allowed. - ITAT
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