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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Fresh adjudication of a confirmed tax demand may proceed only after verification that the entire disputed tax has been recovered or after deposit of any unrecovered balance. The demand was remitted for a final decision on merits, conditional on verification or payment of the disputed tax and submission of a reply to the show-cause notice with supporting documents. If those conditions were not met, recovery could continue in accordance with law after due notice.
Fresh adjudication of a confirmed tax demand may proceed only after verification that the entire disputed tax has been recovered or after deposit of any unrecovered balance. The demand was remitted for a final decision on merits, conditional on verification or payment of the disputed tax and submission of a reply to the show-cause notice with supporting documents. If those conditions were not met, recovery could continue in accordance with law after due notice.
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