Pre-trial bail granted where custodial period, documentary prosecution, and magistrate-triable offence favor release subject to surety and no witness ...
Allowability of Salary Exemptions: Form 16 entries can substantiate HRA and other salary exemptions, and home loan interest is deductible for a self-o...
Capital gains exemption: payment for plot, architect fees and bona fide commencement of construction can satisfy utilisation requirement and secure re...
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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