Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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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