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...
Service of notice and opportunity of hearing were treated as adequate where the director knew of the investigation, sought time to respond, then neither replied nor updated the address despite repeated service attempts. No breach of natural justice arose from non-cooperation. Non-realisation of export proceeds triggered a statutory presumption that reasonable recovery steps had not been taken. As the director was in charge during the contravention and did not establish realisation or efforts to obtain information from the Official Liquidator, company liquidation did not remove liability. The penalty was sustained but confined to the amount already deposited, considering the elapsed period and liquidation.
Service of notice and opportunity of hearing were treated as adequate where the director knew of the investigation, sought time to respond, then neither replied nor updated the address despite repeated service attempts. No breach of natural justice arose from non-cooperation. Non-realisation of export proceeds triggered a statutory presumption that reasonable recovery steps had not been taken. As the director was in charge during the contravention and did not establish realisation or efforts to obtain information from the Official Liquidator, company liquidation did not remove liability. The penalty was sustained but confined to the amount already deposited, considering the elapsed period and liquidation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
