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...
Section 24 requires the Initiating Officer to first issue notice to the alleged benamidar, disclose the reasons for believing the property is benami, and only then seek prior approval for provisional attachment. The Approving Authority must assess the notice and supporting material; approval obtained before notice is mechanical and contrary to the statutory scheme. Accordingly, the confirmed provisional attachment of the jewellery was set aside, while fresh proceedings in accordance with law and all available objections were left open.
Section 24 requires the Initiating Officer to first issue notice to the alleged benamidar, disclose the reasons for believing the property is benami, and only then seek prior approval for provisional attachment. The Approving Authority must assess the notice and supporting material; approval obtained before notice is mechanical and contrary to the statutory scheme. Accordingly, the confirmed provisional attachment of the jewellery was set aside, while fresh proceedings in accordance with law and all available objections were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
