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...
Blocked input tax credit subject to a subsisting Rule 86A restriction cannot be debited, treated as payment, or appropriated towards the mandatory pre-deposit for a GST appeal. The restriction may be challenged or sought to be modified before the competent forum. An erroneous FORM GST DRC-07 attributable to the adjudicating authority, once rectified, should not deprive the taxpayer of the statutory appellate remedy. Electronic filing of the appeal must be enabled, with manual filing available if portal issues persist, subject to compliance with the prescribed pre-deposit.
Blocked input tax credit subject to a subsisting Rule 86A restriction cannot be debited, treated as payment, or appropriated towards the mandatory pre-deposit for a GST appeal. The restriction may be challenged or sought to be modified before the competent forum. An erroneous FORM GST DRC-07 attributable to the adjudicating authority, once rectified, should not deprive the taxpayer of the statutory appellate remedy. Electronic filing of the appeal must be enabled, with manual filing available if portal issues persist, subject to compliance with the prescribed pre-deposit.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
