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...
Interlocutory relief under Rule 29 is contemplated only in a pending appeal. Where a statutory appeal remains under scrutiny and is not registered, stay or early-hearing relief cannot receive substantive consideration. Urgency may instead justify expedited scrutiny, subject to procedural compliance. Once deficiencies are cleared and the appeal is registered, the interlocutory application may be tagged to it and placed before the Bench for consideration.
Interlocutory relief under Rule 29 is contemplated only in a pending appeal. Where a statutory appeal remains under scrutiny and is not registered, stay or early-hearing relief cannot receive substantive consideration. Urgency may instead justify expedited scrutiny, subject to procedural compliance. Once deficiencies are cleared and the appeal is registered, the interlocutory application may be tagged to it and placed before the Bench for consideration.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
