Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Explanation 2A (Significant Economic Presence) was introduced to deem non resident digital activity as a "business connection," but because treaties were not amended, treaty protected residents remained outside SEP's reach; consequently SEP did not apply to the appellant. The tax authority failed to prove a fixed place permanent establishment or dependent agent PE in India: there was no identified place at the disposal of the enterprise, no personnel, agents or equipment in India, and core activities were hosted abroad. The tribunal concluded commission income could not be attributed to an Indian PE and allowed the appeal.
Explanation 2A (Significant Economic Presence) was introduced to deem non resident digital activity as a "business connection," but because treaties were not amended, treaty protected residents remained outside SEP's reach; consequently SEP did not apply to the appellant. The tax authority failed to prove a fixed place permanent establishment or dependent agent PE in India: there was no identified place at the disposal of the enterprise, no personnel, agents or equipment in India, and core activities were hosted abroad. The tribunal concluded commission income could not be attributed to an Indian PE and allowed the appeal.
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