#Section 144C
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508 articlesIncome Tax
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Director’s nationality will not suffice as company incorporated, managed and controlled in UAE
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No further profit attribution to dependent agent PE in India as transaction with Indian AE is at arm’s length
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Royalty payment and R&D on royalty both allowable as revenue expenditure
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Income earned from offshore supply not taxable in India as none of operation is carried out in India
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Order passed in variation of procedures prescribed u/s 144B is non-est and bad-in-law
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Arbitration settlement amount received in relation to project office in India is taxable
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Issuance of draft assessment order along with demand notice is bad in law
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Assessment order violating directions of DRP is liable to be quashed
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Addition based on circular made effective on later date not unsustainable in law
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Disallowance without verifying the submitted details is unsustainable
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Expenditure towards currency swap contract is allowable as deduction u/s 36(1)(iii)
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TPO order passed beyond time limit prescribed u/s 92CA (3A) is barred by limitation
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Order sent on old address without any effort from AO to send on correct address is barred by limitation
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