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...
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Statutory stay of the balance GST demand applies once the prescribed cumulative appellate pre-deposits are paid under the GST enactment. The High Court did not determine whether the required deposits had actually been made or whether recovery from the Electronic Cash Ledger exceeded those deposits. It directed independent consideration of the taxpayer's representation after a personal hearing and required a reasoned and speaking order within the stipulated period. Any recovery found to exceed the cumulative statutory pre-deposits must be refunded or recredited. The underlying merits of the GST demand remain open.
Statutory stay of the balance GST demand applies once the prescribed cumulative appellate pre-deposits are paid under the GST enactment. The High Court did not determine whether the required deposits had actually been made or whether recovery from the Electronic Cash Ledger exceeded those deposits. It directed independent consideration of the taxpayer's representation after a personal hearing and required a reasoned and speaking order within the stipulated period. Any recovery found to exceed the cumulative statutory pre-deposits must be refunded or recredited. The underlying merits of the GST demand remain open.
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