Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Reinsurance premiums from Indian cedants were held not taxable in India where the arrangement did not create a business connection under domestic law nor a permanent establishment under the India-Germany DTAA; the India branch is part of the foreign enterprise, not an agent, and was not involved in direct business so no direct-business income is attributable to it. Payments from the branch to head office for IT and management costs were held not taxable as FTS and not attributable under the attribution rule for a PE. AO directed to recompute MAT properly from returned business loss. Interest on tax refund limited to the treaty interest rate; surcharge and cess deleted.
Reinsurance premiums from Indian cedants were held not taxable in India where the arrangement did not create a business connection under domestic law nor a permanent establishment under the India-Germany DTAA; the India branch is part of the foreign enterprise, not an agent, and was not involved in direct business so no direct-business income is attributable to it. Payments from the branch to head office for IT and management costs were held not taxable as FTS and not attributable under the attribution rule for a PE. AO directed to recompute MAT properly from returned business loss. Interest on tax refund limited to the treaty interest rate; surcharge and cess deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
