PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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The central issue was whether a "virtual service permanent establishment" exists under Article 5(2)(k)/5(6) of the DTAA where no personnel are physically present in India. Relying on treaty-construction principles and Clifford Chance, the court held the DTAA must be strictly construed; Article 5's phrase "within a Contracting State" carries territorial connotation and contemplates physical presence of employees/personnel. Consequently, a virtual service PE not expressly provided by the DTAA or domestic law cannot be recognised, the Revenue's finding was rejected, the impugned NIL-withholding certificate and order were set aside and the matter remanded to the AO for fresh decision within two weeks - HC
The central issue was whether a "virtual service permanent establishment" exists under Article 5(2)(k)/5(6) of the DTAA where no personnel are physically present in India. Relying on treaty-construction principles and Clifford Chance, the court held the DTAA must be strictly construed; Article 5's phrase "within a Contracting State" carries territorial connotation and contemplates physical presence of employees/personnel. Consequently, a virtual service PE not expressly provided by the DTAA or domestic law cannot be recognised, the Revenue's finding was rejected, the impugned NIL-withholding certificate and order were set aside and the matter remanded to the AO for fresh decision within two weeks - HC
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