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 discretion governing appellate admission applies where a penalty does not exceed the prescribed monetary threshold. In an appeal by a managing director against a penalty order issued under section 107, the penalty fell within the threshold for discretion under section 112(2). The Tribunal exercised that discretion to refuse admission, so the appeal was not admitted.
Statutory discretion governing appellate admission applies where a penalty does not exceed the prescribed monetary threshold. In an appeal by a managing director against a penalty order issued under section 107, the penalty fell within the threshold for discretion under section 112(2). The Tribunal exercised that discretion to refuse admission, so the appeal was not admitted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
