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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Sufficient cause supported condonation of delay in a GST appeal where the taxpayer lacked effective knowledge of the show-cause notice and adjudication order because they were uploaded under a non-designated portal tab. Although the Appellate Authority remained bound by the limitation prescribed under section 107 of the RGST/CGST Act, circumstances beyond the taxpayer's control and the risk of grave prejudice justified merits review. The delay was condoned, with a direction to entertain and decide the appeal on merits if filed within the stipulated period.
Sufficient cause supported condonation of delay in a GST appeal where the taxpayer lacked effective knowledge of the show-cause notice and adjudication order because they were uploaded under a non-designated portal tab. Although the Appellate Authority remained bound by the limitation prescribed under section 107 of the RGST/CGST Act, circumstances beyond the taxpayer's control and the risk of grave prejudice justified merits review. The delay was condoned, with a direction to entertain and decide the appeal on merits if filed within the stipulated period.
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