Anti-profiteering obligations survive business demerger, complaint withdrawal, and customized supply arrangements where rate-reduction benefits are no...
Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
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Article 5(2)(l) of the India-USA DTAA requires cumulative satisfaction of services being furnished or performed in India through employees or other personnel for the prescribed period before a service permanent establishment arises. Cost-to-cost reimbursements of expenditure initially incurred and later cross-charged without mark-up do not establish such a presence where the activity is performed remotely and the non-resident's employees or personnel have no physical presence in India. In those circumstances, no service permanent establishment or taxable income in India arises from the reimbursements.
Article 5(2)(l) of the India-USA DTAA requires cumulative satisfaction of services being furnished or performed in India through employees or other personnel for the prescribed period before a service permanent establishment arises. Cost-to-cost reimbursements of expenditure initially incurred and later cross-charged without mark-up do not establish such a presence where the activity is performed remotely and the non-resident's employees or personnel have no physical presence in India. In those circumstances, no service permanent establishment or taxable income in India arises from the reimbursements.
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