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...
Faceless reassessment jurisdiction under section 144B, read with CBDT directions extending faceless assessment to reassessments under section 147, permits both NaFAC and the jurisdictional Assessing Officer to conduct such proceedings. A reassessment completed by NaFAC before notification under section 151A remained valid because it was founded on the existing faceless-assessment mandate, the relevant limitation exclusion did not apply, and subsequent validation supported issuance of reassessment notices by officers other than NaFAC. However, where reassessment was completed ex parte and non-participation was attributed to longstanding mental illness, natural justice required a reasonable opportunity to submit evidence. The additions were remanded for fresh appellate adjudication after three effective opportunities.
Faceless reassessment jurisdiction under section 144B, read with CBDT directions extending faceless assessment to reassessments under section 147, permits both NaFAC and the jurisdictional Assessing Officer to conduct such proceedings. A reassessment completed by NaFAC before notification under section 151A remained valid because it was founded on the existing faceless-assessment mandate, the relevant limitation exclusion did not apply, and subsequent validation supported issuance of reassessment notices by officers other than NaFAC. However, where reassessment was completed ex parte and non-participation was attributed to longstanding mental illness, natural justice required a reasonable opportunity to submit evidence. The additions were remanded for fresh appellate adjudication after three effective opportunities.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
