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...
Pan-India jurisdiction of specified Additional and Joint Commissioners to adjudicate composite DGGI show cause notices rests on the governing notifications. A circular may operationalise that jurisdiction by selecting a common adjudicating authority from officers already competent, but cannot itself confer or enlarge jurisdiction. Selection based on the highest-demand criterion is objective, uniformly applicable and rationally connected to consistent single adjudication, rather than impermissible sub-delegation or arbitrary classification. The notified appellate forum corresponds to the Commissionerate of the common authority. Once a jurisdictional challenge fails, challenges on merits, evidence and natural justice must proceed through the statutory appeal, with merits remaining open.
Pan-India jurisdiction of specified Additional and Joint Commissioners to adjudicate composite DGGI show cause notices rests on the governing notifications. A circular may operationalise that jurisdiction by selecting a common adjudicating authority from officers already competent, but cannot itself confer or enlarge jurisdiction. Selection based on the highest-demand criterion is objective, uniformly applicable and rationally connected to consistent single adjudication, rather than impermissible sub-delegation or arbitrary classification. The notified appellate forum corresponds to the Commissionerate of the common authority. Once a jurisdictional challenge fails, challenges on merits, evidence and natural justice must proceed through the statutory appeal, with merits remaining open.
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TaxTMI 
TaxTMI 
of 4886 
