Income Tax – Supervisory Permanent Establishment under Article 5(4), Taxability of profits from offshore supply of goods, Reimbursement of salary of seconded expatriates and estoppel, Attribution of loan guarantee fee to alleged PE, Attribution of loan guarantee fee to alleged PE – Appellant, a comp...
Income Tax – Disallowance u/s 40(a)(i) for short deduction of tax at source on interest paid to a non-resident – Appellant, engaged in generation and sale of solar power, paid interest to a Mauritius company and deducted tax at source at 7.5% relying on Article 11 of the India-Mauritius DTAA read wi...
Income Tax - Mark-up on reimbursement of salary and travel cost of employees seconded to AE, Deduction of amalgamation expenditure in the fifth year where the appointed date of amalgamation precedes the year of expenditure - Appellant, engaged in provision of IT services and IT-enabled services, rec...
Income Tax - Validity of notice under Section 148 of the Income Tax Act, 1961 issued beyond four years on the basis of difference between turnover in VAT returns and books of accounts - A survey under Section 133A was conducted at the place of business of the Petitioner. The Investigation Wing obser...
Income Tax – Jurisdiction of Prescribed Income-tax Authority to issue notice under Section 143(2) of the Income Tax Act, 1961 in a centralised case - The case of the Petitioner stood centralised with the Assessing Officer after a search and seizure operation under Section 132. For the assessment yea...