Back-end operations do not constitute Permanent establishment
Mere back-end operations outfit is held to be excluded from the term “permanent establishment” and classified as one for the…
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Today's
No fetters on AO in dealing with stay applications ......Read More
Yesterday's AO not bound by departmental instruction for 20% payment as a precondition for grant of stay pending appeal ......Read More
Yesterday's AO not bound by departmental instruction for 20% payment as a precondition for grant of stay pending appeal ......Read More
Most Favoured Nation clause (MFN) in tax treatise is made most difficult to give effect to
In the matter of interpretation of treaties the Supreme Court in their decision in [2021] 432 ITR 471 (SC) held…
......Read MoreOutsourcing/sub-contracting could sense grey area in NR PE factor- IBM case scenario
In an interesting situation IBM India obtained a contract to undertake payroll and data management function for P&G India in…
......Read MoreNotional Provisions are not taxable even if so appearing in 26AS
Only because the other party has made a notional provision in its books and made a deduction of tax and…
......Read MoreUnbecoming of Tribunal
The Kolkata bench of ITAT in [2023] 32 ITR (Trib)-OL 533 (ITAT[Kolk]) held that the income earned from testing services is taxable…
......Read MoreWHETHER ASSESSEE CAN RESILE FROM MOST APPROPRIATE METHOD ADOPTED IN ITS TP REPORT
The transfer pricing report and the most appropriate method adopted by the assessee is not sacrosanct and may require a…
......Read MoreShare application money pending allotment
Before the Tribunal in [2023] 32 ITR (Trib)-OL 253 (ITAT[Mum]) the bench had to decide whether the share application money…
......Read MoreTPO Activism
Vide Case Reference: [2022] 447 ITR 585 (All) the instructions issued by the board u/s 119 need to be implemented…
......Read MoreDomain name Regd , web hosting and sponsorship fee
Domain name registration and web hosting are not covered in royalty ambit. Likewise sponsorship fees for hosting conference is not…
......Read MoreEyewash proviso
In a case of transaction of purchase of immovable property from a non resident it is mandatory to deduct tax…
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