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...
GST reimbursement under the contractual tax-transition notification must be assessed under paragraph 4 for post-GST contracts and ongoing projects with estimates approved before 1 July 2017, applying GST rates. Paragraph 3(iv), confined to pre-GST contracts, cannot govern or defeat claims concerning contracts executed after that date. The reimbursement claim requires reconsideration under paragraph 4 following a personal hearing and a reasoned decision; coercive action remains restrained pending that determination.
GST reimbursement under the contractual tax-transition notification must be assessed under paragraph 4 for post-GST contracts and ongoing projects with estimates approved before 1 July 2017, applying GST rates. Paragraph 3(iv), confined to pre-GST contracts, cannot govern or defeat claims concerning contracts executed after that date. The reimbursement claim requires reconsideration under paragraph 4 following a personal hearing and a reasoned decision; coercive action remains restrained pending that determination.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
