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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Section 74 does not permit a single show-cause notice to club multiple financial years, because limitation is linked to each relevant financial year and a consolidated notice would unlawfully extend the five-year period for earlier years. The impugned notice and consequential order were therefore treated as de hors the statute and without jurisdiction. The alternative-remedy rule was also held to be only a self-imposed restraint: where the defect is ex facie jurisdictional and apparent on the record, writ relief remains maintainable despite an available statutory appeal.
Section 74 does not permit a single show-cause notice to club multiple financial years, because limitation is linked to each relevant financial year and a consolidated notice would unlawfully extend the five-year period for earlier years. The impugned notice and consequential order were therefore treated as de hors the statute and without jurisdiction. The alternative-remedy rule was also held to be only a self-imposed restraint: where the defect is ex facie jurisdictional and apparent on the record, writ relief remains maintainable despite an available statutory appeal.
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