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...
Cash and transfer entries from a subsequent financial year were included in the Assessment Year 2022-23 assessment, despite the relevant year being Financial Year 2021-22. The High Court treated the unresolved revisional challenge to those entries as material and held that its inadequate consideration vitiated both the assessment and revisional orders. Those orders were set aside, and the assessing authority must make a fresh determination within two months in accordance with law. The merits of the unexplained cash-deposit addition remain open.
Cash and transfer entries from a subsequent financial year were included in the Assessment Year 2022-23 assessment, despite the relevant year being Financial Year 2021-22. The High Court treated the unresolved revisional challenge to those entries as material and held that its inadequate consideration vitiated both the assessment and revisional orders. Those orders were set aside, and the assessing authority must make a fresh determination within two months in accordance with law. The merits of the unexplained cash-deposit addition remain open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
