Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
An assessee-company's residential status for tax purposes had to be determined on the factual and legal basis for locating its place of effective management, not on the institutional status of the authority that earlier considered the matter. The Tribunal found that the material showing effective control was not exercised abroad had merit, and that the Assessing Officer had not rebutted the factual foundation relied on to place POEM in India. As the first appellate authority accepted that the collegium's basis lacked merit, it could not sustain the assessment merely because it was reluctant to differ from that collegium. The POEM finding in India was therefore unsustainable, and the global income addition was deleted.
An assessee-company's residential status for tax purposes had to be determined on the factual and legal basis for locating its place of effective management, not on the institutional status of the authority that earlier considered the matter. The Tribunal found that the material showing effective control was not exercised abroad had merit, and that the Assessing Officer had not rebutted the factual foundation relied on to place POEM in India. As the first appellate authority accepted that the collegium's basis lacked merit, it could not sustain the assessment merely because it was reluctant to differ from that collegium. The POEM finding in India was therefore unsustainable, and the global income addition was deleted.
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