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...
Independent corroboration was required to sustain a penalty for alleged involvement in an attempted export of prohibited red sanders where the allegation rested solely on statements later retracted. Retraction placed on record required consideration, and an uncorroborated retracted statement could not alone establish liability. The setting aside of penalty against the person alleged to have introduced the employee to the purported mastermind also removed the factual basis for penalising the employee. The penalty was therefore unsustainable and the appeal succeeded.
Independent corroboration was required to sustain a penalty for alleged involvement in an attempted export of prohibited red sanders where the allegation rested solely on statements later retracted. Retraction placed on record required consideration, and an uncorroborated retracted statement could not alone establish liability. The setting aside of penalty against the person alleged to have introduced the employee to the purported mastermind also removed the factual basis for penalising the employee. The penalty was therefore unsustainable and the appeal succeeded.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
