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 opportunity of personal hearing in GST adjudication requires that the hearing be scheduled after expiry of the deadline for replying to the show-cause notice. Scheduling it earlier makes the hearing illusory because the taxpayer cannot first submit the permitted response, thereby breaching principles of natural justice. Adjudication and appellate orders passed in these circumstances were quashed, with fresh proceedings to recommence from the show-cause notice stage after allowing a reply and then fixing a personal hearing.
Effective opportunity of personal hearing in GST adjudication requires that the hearing be scheduled after expiry of the deadline for replying to the show-cause notice. Scheduling it earlier makes the hearing illusory because the taxpayer cannot first submit the permitted response, thereby breaching principles of natural justice. Adjudication and appellate orders passed in these circumstances were quashed, with fresh proceedings to recommence from the show-cause notice stage after allowing a reply and then fixing a personal hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
