Foreign portfolio investment liberalisation extends listed equity access to all individual persons resident outside India, subject to limit monitoring...
Unsubstantiated exempt agricultural income claim sustains concealment penalty after disclosure only on departmental detection and no bona fide evidenc...
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The branch office in India was treated as a continuation of the earlier liaison office, because the RBI approval and the nature of the upgraded arrangement showed an enlarged continuation of the existing presence rather than a new setup. On that basis, the Tribunal recorded that the branch office constituted a permanent establishment in India. As the taxability and profit attribution issues for the year were similar to those already remanded in earlier years, the matter was restored to the Assessing Officer for de novo examination, including the assessee's claim that the branch office served only the machinery division.
The branch office in India was treated as a continuation of the earlier liaison office, because the RBI approval and the nature of the upgraded arrangement showed an enlarged continuation of the existing presence rather than a new setup. On that basis, the Tribunal recorded that the branch office constituted a permanent establishment in India. As the taxability and profit attribution issues for the year were similar to those already remanded in earlier years, the matter was restored to the Assessing Officer for de novo examination, including the assessee's claim that the branch office served only the machinery division.
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