Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
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Dependent agent permanent establishment under Article 5(5) of the India-Switzerland DTAA requires cogent evidence that an Indian intermediary both has authority to negotiate and enter contracts for the foreign enterprise and habitually exercises that authority. Customer liaison, account management, administrative support, communicating pre-approved terms, and assisting an online contracting process do not satisfy that test where material commercial decisions remain offshore. Group control or economic dependence cannot replace the positive authority requirement, though they may affect independent-agent status. PE existence must be determined before Article 7 profit attribution; arm's-length remuneration does not itself prevent a DAPE, but may affect attribution if a PE exists. Rule 10 becomes relevant only where income cannot be definitely ascertained.
Dependent agent permanent establishment under Article 5(5) of the India-Switzerland DTAA requires cogent evidence that an Indian intermediary both has authority to negotiate and enter contracts for the foreign enterprise and habitually exercises that authority. Customer liaison, account management, administrative support, communicating pre-approved terms, and assisting an online contracting process do not satisfy that test where material commercial decisions remain offshore. Group control or economic dependence cannot replace the positive authority requirement, though they may affect independent-agent status. PE existence must be determined before Article 7 profit attribution; arm's-length remuneration does not itself prevent a DAPE, but may affect attribution if a PE exists. Rule 10 becomes relevant only where income cannot be definitely ascertained.
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