Lg Electronics India Pvt. Ltd., Uttar ... vs Assessee
आयकर अऩीऱीय अधधकरण, ददल्ऱी विशेष न्यायऩीठ, नई
primacy of 'location test" of the basic rule is consistent with the
conceptual structure of the PE clause itself. An agency will constitute ... basic
rule which are altered or replaced by the agency clause. OECD and UN
Model Treaties recognize agency PE. The principle being, that a foreign
primacy of 'location test" of the basic
rule is consistent with the conceptual structure of the PE clause itself. An agency will
constitute ... basic
rule which are altered or replaced by the agency clause. OECD and UN Model Treaties
recognize agency PE. The principle being, that a foreign
substance over form"
principle or "piercing the corporate veil" test and disregard the
transaction/structure, if there is abuse of organization/legal ... authorities examine a related and associated parties
transaction as actually undertaken and structured by the parties.
Normally, tax authorities cannot disregard the actual transaction
substance over form"
principle or "piercing the corporate veil" test and disregard the
transaction/structure, if there is abuse of organization/legal ... authorities examine a related and associated parties
transaction as actually undertaken and structured by the parties.
Normally, tax authorities cannot disregard the actual transaction
Hyundai Groups of
Companies' and such agreement cannot override the basic accountings principles.
This is particularly so when I find that the said agreement ... acceptable. Even if
the said agreement is to be believed, the payment structure for the year under
examination clearly shows that
basis of Plinth Area Rates and Cost Index Method for the basic
structural work of the building and accounts method for finishing
items ... basis of Plinth Area Rates and Cost Index Method for the basic
structural work of the building and accounts method for finishing
items
M/S. New Delhi Television Ltd., New ... vs Dcit, New Delhi on 14 July, 2017
Ranbaxy Laboratories Ltd. vs Addl. Commissioner Of Income Tax, Range ... on 22 January, 2008
Equivalent
Motorola Inc., Erisson Radio Systems ... vs Deputy C.I.T. on 22 June, 2005
Equivalent