Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic.
Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic.
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