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...
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Fresh adjudication was permitted where the petitioner had not participated in the original proceedings and the statutory appellate limitation had expired. The impugned order was quashed, subject to an additional pre-deposit of 25% of the disputed tax and submission of a reply to the show-cause notice within the stipulated period. The earlier order was to operate as an addendum to the show-cause notice for the fresh proceedings. No further extension or concession was available; failure to comply allowed recovery proceedings to continue in accordance with law after due notice.
Fresh adjudication was permitted where the petitioner had not participated in the original proceedings and the statutory appellate limitation had expired. The impugned order was quashed, subject to an additional pre-deposit of 25% of the disputed tax and submission of a reply to the show-cause notice within the stipulated period. The earlier order was to operate as an addendum to the show-cause notice for the fresh proceedings. No further extension or concession was available; failure to comply allowed recovery proceedings to continue in accordance with law after due notice.
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