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...
Effective service of a rectification notice is required before adjudicating a refund of accumulated input tax credit under an inverted duty structure. Adjudication after the notice was returned undelivered breached principles of natural justice because the claimant was denied an opportunity of hearing. The refund rejection was set aside and remitted for fresh adjudication after granting a hearing, while leaving the merits of the refund claim open.
Effective service of a rectification notice is required before adjudicating a refund of accumulated input tax credit under an inverted duty structure. Adjudication after the notice was returned undelivered breached principles of natural justice because the claimant was denied an opportunity of hearing. The refund rejection was set aside and remitted for fresh adjudication after granting a hearing, while leaving the merits of the refund claim open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
