Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Disallowance arose over a gratuity expense claimed where one transferred employee's gratuity liability was moved to a related concern. Tribunal reasoned that transferring the liability to the other concern constituted discharge of the assessee's obligation akin to actual payment, because the employee had rendered services to the assessee and the liability was validly shifted; accordingly the gratuity expense was allowable and the appeal was allowed by the ITAT.
Disallowance arose over a gratuity expense claimed where one transferred employee's gratuity liability was moved to a related concern. Tribunal reasoned that transferring the liability to the other concern constituted discharge of the assessee's obligation akin to actual payment, because the employee had rendered services to the assessee and the liability was validly shifted; accordingly the gratuity expense was allowable and the appeal was allowed by the ITAT.
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