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...
An e-way bill showing a wholly different vehicle number generated differing views on whether a penalty for tax-evasion intent could arise. The Judicial Member considered correct Part B vehicle particulars mandatory, treated post-interception correction as ineffective, and found that the circumstances created a rebuttable presumption of evasion that remained unrebutted. The Technical Member treated invoices and commercial records showing the correct vehicle as evidence of a genuine transaction, concluding that a mismatch alone, absent a finding of evasion intent, could not support penalty. The point of difference was referred to another Member; the departmental appeal remains undecided.
An e-way bill showing a wholly different vehicle number generated differing views on whether a penalty for tax-evasion intent could arise. The Judicial Member considered correct Part B vehicle particulars mandatory, treated post-interception correction as ineffective, and found that the circumstances created a rebuttable presumption of evasion that remained unrebutted. The Technical Member treated invoices and commercial records showing the correct vehicle as evidence of a genuine transaction, concluding that a mismatch alone, absent a finding of evasion intent, could not support penalty. The point of difference was referred to another Member; the departmental appeal remains undecided.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
