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...
Section 32A protection extends the clean slate principle to a corporate debtor sold as a going concern during liquidation, subject to fulfilment of statutory conditions. Unclaimed past liabilities, pending or future proceedings, and pre-existing non-compliances cannot continue against the purchaser after completion of the sale where the statutory protection applies. This consequence arises by operation of law rather than as a discretionary waiver or concession. Purchasers seeking waivers or concessions concerning past liabilities must pursue those requests before the relevant statutory authorities.
Section 32A protection extends the clean slate principle to a corporate debtor sold as a going concern during liquidation, subject to fulfilment of statutory conditions. Unclaimed past liabilities, pending or future proceedings, and pre-existing non-compliances cannot continue against the purchaser after completion of the sale where the statutory protection applies. This consequence arises by operation of law rather than as a discretionary waiver or concession. Purchasers seeking waivers or concessions concerning past liabilities must pursue those requests before the relevant statutory authorities.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4896 
