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...
GST show cause notices initiate, rather than conclusively determine, tax liability. Statutory adjudication must consider the registered person's reply; recording the reply as unsatisfactory does not preclude independent examination of whether it received adequate consideration. Objections concerning audit findings, limitation, tax computation and treatment of deposits fall for determination by the Adjudicating Authority. Writ intervention should not ordinarily pre-empt that statutory process, and substantive objections remain available during adjudication.
GST show cause notices initiate, rather than conclusively determine, tax liability. Statutory adjudication must consider the registered person's reply; recording the reply as unsatisfactory does not preclude independent examination of whether it received adequate consideration. Objections concerning audit findings, limitation, tax computation and treatment of deposits fall for determination by the Adjudicating Authority. Writ intervention should not ordinarily pre-empt that statutory process, and substantive objections remain available during adjudication.
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TaxTMI 
TaxTMI 
of 4878 
