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...
Constitutional validity of the input tax credit condition requiring a supplier's actual tax payment is under Supreme Court consideration. The challenge concerns denial of credit to a bona fide purchaser where the supplier has not remitted tax, including arguments for reading down the condition to prevent double taxation and to satisfy Article 14 equality requirements. The Supreme Court issued notice, stayed the High Court judgment and orders, and listed the matter for final disposal.
Constitutional validity of the input tax credit condition requiring a supplier's actual tax payment is under Supreme Court consideration. The challenge concerns denial of credit to a bona fide purchaser where the supplier has not remitted tax, including arguments for reading down the condition to prevent double taxation and to satisfy Article 14 equality requirements. The Supreme Court issued notice, stayed the High Court judgment and orders, and listed the matter for final disposal.
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TaxTMI 
TaxTMI 
of 4894 
