Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Assessment against deceased sole proprietor requires proceedings against the legal representative, rendering prior assessment and appellate orders inv...
Residential waste collection classification under SAC 999423 defeats composite-supply exemption where facilitating goods are not transferred to the lo...
Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
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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.
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