Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
