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...
Rejection of declared FOB value and denial of drawback for readymade garments exported under 63 shipping bills were unsustainable because the proceedings relied exclusively on an investigation into separate March 2017 exports. Export remittances matching the declared FOB value had been received, while departmental costing material did not establish overvaluation. No independent enquiry addressed the 63 shipping bills. Consequently, the demand, FOB-value rejection and penalties were set aside, and the appeal succeeded with consequential relief.
Rejection of declared FOB value and denial of drawback for readymade garments exported under 63 shipping bills were unsustainable because the proceedings relied exclusively on an investigation into separate March 2017 exports. Export remittances matching the declared FOB value had been received, while departmental costing material did not establish overvaluation. No independent enquiry addressed the 63 shipping bills. Consequently, the demand, FOB-value rejection and penalties were set aside, and the appeal succeeded with consequential relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
