Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Scrutiny-based show cause notices for unreconciled input tax credit were treated as distinct from earlier audit-based proceedings, and the overlap with the prior section 73 action could not be resolved at the notice stage without a reply. The court held that, where the record suggests possible non-payment or short payment by reason of fraud, wilful misstatement or suppression, a section 74 notice may be issued. The challenge was therefore not entertained at issuance, and the taxpayer was directed to respond before final adjudication.
Scrutiny-based show cause notices for unreconciled input tax credit were treated as distinct from earlier audit-based proceedings, and the overlap with the prior section 73 action could not be resolved at the notice stage without a reply. The court held that, where the record suggests possible non-payment or short payment by reason of fraud, wilful misstatement or suppression, a section 74 notice may be issued. The challenge was therefore not entertained at issuance, and the taxpayer was directed to respond before final adjudication.
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