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...
Rule 86A blocking of an electronic credit ledger is a provisional measure that requires recorded reasons and cannot continue beyond one year. Filing an appeal with the prescribed pre-deposit creates a deemed stay of recovery for the remaining demand, preventing appropriation from the electronic cash ledger and the blocked credit ledger. That recovery stay does not automatically lift the separate Rule 86A blocking order. Unblocking must be sought independently, and any refusal should be issued through a speaking order after consideration of the request.
Rule 86A blocking of an electronic credit ledger is a provisional measure that requires recorded reasons and cannot continue beyond one year. Filing an appeal with the prescribed pre-deposit creates a deemed stay of recovery for the remaining demand, preventing appropriation from the electronic cash ledger and the blocked credit ledger. That recovery stay does not automatically lift the separate Rule 86A blocking order. Unblocking must be sought independently, and any refusal should be issued through a speaking order after consideration of the request.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
