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...
Statutory limitation on customs demands restricts the Department from initiating or enforcing a fresh demand, but does not bar settlement-stage appropriation of differential duty voluntarily deposited for earlier imports. Where liability is admitted and the deposit is neither retracted nor controverted, it may be adjusted against that liability. Judicial review of a settlement order remains confined to jurisdictional error, denial of natural justice, manifest legal error, or findings unsupported by the record; it does not permit reappraisal of unchallenged factual findings. The voluntary-duty appropriation therefore remained undisturbed.
Statutory limitation on customs demands restricts the Department from initiating or enforcing a fresh demand, but does not bar settlement-stage appropriation of differential duty voluntarily deposited for earlier imports. Where liability is admitted and the deposit is neither retracted nor controverted, it may be adjusted against that liability. Judicial review of a settlement order remains confined to jurisdictional error, denial of natural justice, manifest legal error, or findings unsupported by the record; it does not permit reappraisal of unchallenged factual findings. The voluntary-duty appropriation therefore remained undisturbed.
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TaxTMI 
TaxTMI 
of 4886 
