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...
Fixed "refurbish and rebate" credit notes issued to distributors for defective products did not constitute consideration for contract work where the credit was uniformly calculated at 30% of the original price, regardless of repair cost or whether repairs occurred, and distributors were not obliged to repair. Consequently, tax was not required to be deducted at source and the related disallowance was deleted. Employees' welfare contributions require verification against statutory due dates using challans and supporting material where the tax audit report's payment dates are disputed. Contributions paid within the prescribed due dates must be allowed; the issue was remanded for limited verification.
Fixed "refurbish and rebate" credit notes issued to distributors for defective products did not constitute consideration for contract work where the credit was uniformly calculated at 30% of the original price, regardless of repair cost or whether repairs occurred, and distributors were not obliged to repair. Consequently, tax was not required to be deducted at source and the related disallowance was deleted. Employees' welfare contributions require verification against statutory due dates using challans and supporting material where the tax audit report's payment dates are disputed. Contributions paid within the prescribed due dates must be allowed; the issue was remanded for limited verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
