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...
Rice bran oil and de-oiled rice bran produced through technical extraction and refining are manufactured commodities, not processed agricultural produce. The Schedule cannot expand the statutory definition of agricultural produce; executive inclusion of those products, consequential market-fee demands, and associated orders were invalid, with refund of paid fees directed. Market-fee amendments did not directly or immediately restrict movement of goods under Article 301 and did not require prior Presidential sanction. The special deemed-sale definition validly prevents fee evasion and is compatible with the Sale of Goods Act. Availability of market-wide regulatory services, rather than actual individual use, supports a fee levy on covered produce. Industrial and agricultural-market regulation operate in distinct fields, so no repugnancy arises.
Rice bran oil and de-oiled rice bran produced through technical extraction and refining are manufactured commodities, not processed agricultural produce. The Schedule cannot expand the statutory definition of agricultural produce; executive inclusion of those products, consequential market-fee demands, and associated orders were invalid, with refund of paid fees directed. Market-fee amendments did not directly or immediately restrict movement of goods under Article 301 and did not require prior Presidential sanction. The special deemed-sale definition validly prevents fee evasion and is compatible with the Sale of Goods Act. Availability of market-wide regulatory services, rather than actual individual use, supports a fee levy on covered produce. Industrial and agricultural-market regulation operate in distinct fields, so no repugnancy arises.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
