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...
Wrongful treatment of an individual as a company's Principal Officer can undermine criminal prosecution for delayed deposit of tax deducted at source when the prosecution is founded on an incorrect assertion that the individual was a director. The show-cause notice, designation order, sanction and complaint must rest on accurate corporate status. Where the Department accepts that the accused was never a director, vicarious liability cannot be sustained on that premise; the prosecution was quashed on its particular facts without precedential effect.
Wrongful treatment of an individual as a company's Principal Officer can undermine criminal prosecution for delayed deposit of tax deducted at source when the prosecution is founded on an incorrect assertion that the individual was a director. The show-cause notice, designation order, sanction and complaint must rest on accurate corporate status. Where the Department accepts that the accused was never a director, vicarious liability cannot be sustained on that premise; the prosecution was quashed on its particular facts without precedential effect.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
