Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Treaty residency under the India-US DTAA turned on the tie-break test, especially the assessee's centre of vital interests. The Tribunal noted that personal ties could point to the US because the immediate family resided there, but economic ties appeared substantially rooted in India. Because critical facts on family residence, US-return income breakup, and prior-year treatment were not adequately established, the matter could not be decided on the existing record. Applying the approach in Ashok Kumar Pandey, the Tribunal required examination of the nucleus family and active commercial involvement, and remanded the case for fresh factual verification and adjudication after giving the assessee an opportunity to be heard.
Treaty residency under the India-US DTAA turned on the tie-break test, especially the assessee's centre of vital interests. The Tribunal noted that personal ties could point to the US because the immediate family resided there, but economic ties appeared substantially rooted in India. Because critical facts on family residence, US-return income breakup, and prior-year treatment were not adequately established, the matter could not be decided on the existing record. Applying the approach in Ashok Kumar Pandey, the Tribunal required examination of the nucleus family and active commercial involvement, and remanded the case for fresh factual verification and adjudication after giving the assessee an opportunity to be heard.
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