Indian subsidiary does not constitute permanent establishment of foreign company in India.
AAR rules on existence of PE with respect to transaction processing fees received by MasterCard from Indian customer banks
Mere non-furnishing of Tax Residency Certificate does not disentitle treaty benefits.
Final rules dealing with special transitional provisions for foreign companies regarded as Indian tax resident in terms of 'Place of Effective Management' (POEM)
Reimbursement of market survey expenses to AE benefitting the Indian taxpayer held to be different from shareholder’s activity
For claiming exemption under section 47(vib) from capital gain on transfer of capital asset by the demerged company to the resulting company in a demerger, the conditions prescribed under section 2(19AA) should be fulfilled
Non-disposal of objections of the assessee against reopening of assessment would not make reassessment order void ab initio
The Tax Tribunal allowed exemption under section 10AA of the Act by importing definition of ‘service’ from SEZ Act and Rules
Consent/Settlement charges paid to SEBI is an allowable business expense
Share valuation can be challenged by the tax authorities in the absence of verification of the figures furnished by the assessee to Merchant Banker.
Interest Income from share application money can be adjusted against public issue expenses.
Amendment in Section 89 and Section 90 of Companies Act, 2013 and notification of Companies (Significant Beneficial Owners) Rules, 2018