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...
Review jurisdiction permits reliance on newly discovered evidence only where, despite due diligence, it was neither known nor capable of earlier production. Publicly available sale deeds and a Tribunal order did not meet that condition because they were accessible during the original proceedings and no due diligence was demonstrated. Seeking to reassess the factual explanation for an unexplained bank credit would amount to an impermissible rehearing rather than correction of an error apparent on the record. The review application was therefore dismissed.
Review jurisdiction permits reliance on newly discovered evidence only where, despite due diligence, it was neither known nor capable of earlier production. Publicly available sale deeds and a Tribunal order did not meet that condition because they were accessible during the original proceedings and no due diligence was demonstrated. Seeking to reassess the factual explanation for an unexplained bank credit would amount to an impermissible rehearing rather than correction of an error apparent on the record. The review application was therefore dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
