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...
Documents relied upon in a respondent's complaint and relevant to whether property attachment should continue during the complaint's pendency must be taken on record in the related appeals. The refusal to admit those documents was set aside, and documents already filed were treated as part of the record. Costs imposed for delayed applications to file documents remained payable because the appellants had the documents in their knowledge and possession but sought to place them on record only when the appeals were listed for final hearing.
Documents relied upon in a respondent's complaint and relevant to whether property attachment should continue during the complaint's pendency must be taken on record in the related appeals. The refusal to admit those documents was set aside, and documents already filed were treated as part of the record. Costs imposed for delayed applications to file documents remained payable because the appellants had the documents in their knowledge and possession but sought to place them on record only when the appeals were listed for final hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
