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...
Territorial jurisdiction over an income-tax appeal and a related cross-objection is ordinarily determined by the office location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the appellate authority. Where the assessment order originated from the Chennai Assessing Officer, the Mumbai Bench lacked jurisdiction over both proceedings. The appeal and cross-objection were dismissed without examination on merits, with liberty to approach the appropriate Bench. Merits remained open, and time spent before the Mumbai Bench may be considered under delay-condonation law.
Territorial jurisdiction over an income-tax appeal and a related cross-objection is ordinarily determined by the office location of the Assessing Officer who issued the assessment order, rather than the assessee's location or that of the appellate authority. Where the assessment order originated from the Chennai Assessing Officer, the Mumbai Bench lacked jurisdiction over both proceedings. The appeal and cross-objection were dismissed without examination on merits, with liberty to approach the appropriate Bench. Merits remained open, and time spent before the Mumbai Bench may be considered under delay-condonation law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
