1

Commissioner (A) is not empowered to enhance income a new source of income vide 82ITR 9Trib) 176
1

It is assessee’s choice to select a method for determining FMV of shares vide 81 ITR (Trib) (SN) 78
1

No TP adjustment of trade receivables in case of a debt-free company vide 81ITR (Trib) (SN) 94
1

To accord registration as a charitable institution under income tax dominant purpose must be charitable and satisfies the conditions laid down us 2(15) vide 426ITR108 despite having non charitable ancillary objects meant to achieve the dominant purpose
1

Transactions with dubious entities is reason enough for case reopening vide 421ITR624

Back-end operations do not constitute Permanent establishment

ByCA Gopal Nathani

Nov 17, 2023

Mere back-end operations outfit is held to be excluded from the term “permanent establishment” and classified as one for the supply of information and not chargeable to tax vide (2023] 21 ITR-OL 369 (Bom).

In this case from the scrutiny of documents found during survey there was no any document suggesting that substantial business had been done from the liaison office of Mauritius entity.

In this case the revenue failed to establish that any substantial business has been done from the Mumbai office of Mauritian entity.