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...
Inverted duty structure refund computation requires accurate determination of turnover of inverted-rated supplies and adjusted total turnover. The treatment of outward supplies allegedly taxable at a higher rate must be verified before deciding whether they form part of the relevant turnover figures. Where supporting invoices or other documents are unavailable and the relevant issue has not been examined, the admissible accumulated input tax credit refund cannot be correctly quantified. Refund computation requires fresh examination after production of relevant records and a reasonable opportunity for both sides to address the turnover treatment.
Inverted duty structure refund computation requires accurate determination of turnover of inverted-rated supplies and adjusted total turnover. The treatment of outward supplies allegedly taxable at a higher rate must be verified before deciding whether they form part of the relevant turnover figures. Where supporting invoices or other documents are unavailable and the relevant issue has not been examined, the admissible accumulated input tax credit refund cannot be correctly quantified. Refund computation requires fresh examination after production of relevant records and a reasonable opportunity for both sides to address the turnover treatment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
