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...
Section 93 of the CGST Act permits post-death determination of tax, interest or penalty through a legal representative, without requiring adjudication to have begun during the deceased's lifetime. Liability remains confined to estate assets and does not attribute the underlying contravention to the representative; effective hearing and appellate safeguards support its constitutional validity. Pure questions concerning Section 93 may be examined in writ jurisdiction despite an alternative remedy, but factual and merits disputes, including service, proof, representative-liability conditions and penalty computation, belong in statutory appeal. Retention or appropriation of investigation deposits requires a disclosed lawful basis and reasoned determination after hearing; any unsupported balance must be released with accrued fixed-deposit interest.
Section 93 of the CGST Act permits post-death determination of tax, interest or penalty through a legal representative, without requiring adjudication to have begun during the deceased's lifetime. Liability remains confined to estate assets and does not attribute the underlying contravention to the representative; effective hearing and appellate safeguards support its constitutional validity. Pure questions concerning Section 93 may be examined in writ jurisdiction despite an alternative remedy, but factual and merits disputes, including service, proof, representative-liability conditions and penalty computation, belong in statutory appeal. Retention or appropriation of investigation deposits requires a disclosed lawful basis and reasoned determination after hearing; any unsupported balance must be released with accrued fixed-deposit interest.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
