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...
Reliance on a previously quashed departmental circular could not sustain rejection of an inverted-duty refund claim for cotton-yarn clearances. High Court quashed the appellate order because it rested on that circular and required fresh examination of the inputs procured and their use in manufacturing and clearing cotton yarn before refund eligibility could be determined. The refund claims were remitted for fresh examination, with refund to be granted if eligibility is established.
Reliance on a previously quashed departmental circular could not sustain rejection of an inverted-duty refund claim for cotton-yarn clearances. High Court quashed the appellate order because it rested on that circular and required fresh examination of the inputs procured and their use in manufacturing and clearing cotton yarn before refund eligibility could be determined. The refund claims were remitted for fresh examination, with refund to be granted if eligibility is established.
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TaxTMI 
TaxTMI 
of 4878 
