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...
The statutory bar on admission of an advance-ruling application applies where the same question concerning the applicant is already pending or has been decided in proceedings. A transporter's supply-characterisation question-whether making vehicles available to another goods transport agency is exempt or taxable-formed the basis of a pending input-tax-credit reversal proceeding and had been decided for an earlier tax period. Both grounds precluded examination of classification, exemption, or taxability on the merits, and the application was rejected as not maintainable.
The statutory bar on admission of an advance-ruling application applies where the same question concerning the applicant is already pending or has been decided in proceedings. A transporter's supply-characterisation question-whether making vehicles available to another goods transport agency is exempt or taxable-formed the basis of a pending input-tax-credit reversal proceeding and had been decided for an earlier tax period. Both grounds precluded examination of classification, exemption, or taxability on the merits, and the application was rejected as not maintainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
