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...
Liquidation-process amendments apply prospectively unless expressly made retrospective. A liquidation order fixing the liquidation commencement date and directing the liquidator to explore sale of the corporate debtor as a going concern initiates the governing process; later auction and sale steps merely implement it. A subsequent amendment therefore cannot alter rights and obligations under the regime applicable on that date. The Tribunal set aside retrospective application of the amendment and remanded consequential reliefs and concessions for fresh consideration according to law.
Liquidation-process amendments apply prospectively unless expressly made retrospective. A liquidation order fixing the liquidation commencement date and directing the liquidator to explore sale of the corporate debtor as a going concern initiates the governing process; later auction and sale steps merely implement it. A subsequent amendment therefore cannot alter rights and obligations under the regime applicable on that date. The Tribunal set aside retrospective application of the amendment and remanded consequential reliefs and concessions for fresh consideration according to law.
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TaxTMI 
TaxTMI 
of 4894 
