Steel-timber construction shuttering/formwork tariff classification dispute: essential character held steel, classified as shuttering under Heading 73...
Family-linked property purchases using fabricated loan agreements and benami-style arrangements held to be crime proceeds; attachment upheld, appeal d...
Charitable tree plantation and maintenance for environmental preservation treated as "charitable activity", exempt from GST under Notification 12/2017...
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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