International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
The issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
The issue is whether the assessee was an agent of an NRI partner such that income received by a partnership would be attributable to the assessee; the tribunal found the development agreement was with the partnership firm (five partners) not the individual NRI, there was no direct or indirect contractual or business connection between the assessee and the NRI partner, and income flowed to partners from the firm; therefore the tax authority failed to establish agency and the addition made invoking agent-attribution provisions was deleted in favour of the assessee.
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