Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
Payments to medical consultants were held to be for independent professional services rather than salaried employment because consultancy agreements established a principaltoprincipal relationship. The consultants retained control over manner of service, and contractual supervision measures (fixed hours, reporting, leave rules, exclusivity clauses) did not convert a contract for service into a contract of service. Where consultants declared the income in their tax returns, the payer could not be treated as an assessee in default for TDS; the appeal by revenue was dismissed accordingly.
Payments to medical consultants were held to be for independent professional services rather than salaried employment because consultancy agreements established a principaltoprincipal relationship. The consultants retained control over manner of service, and contractual supervision measures (fixed hours, reporting, leave rules, exclusivity clauses) did not convert a contract for service into a contract of service. Where consultants declared the income in their tax returns, the payer could not be treated as an assessee in default for TDS; the appeal by revenue was dismissed accordingly.
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