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...
Doctrine of merger did not apply where a statutory appeal against GST registration cancellation was summarily dismissed as time-barred; the original cancellation order therefore remained open to challenge under Articles 226 and 227. HC held that dismissal on limitation did not bar writ relief. On the registrant's bona fide explanation for failing to answer the show-cause notice, HC adopted a justice-oriented approach, quashed the cancellation, and directed restoration conditional on timely filing of returns and payment of outstanding tax, interest and penalty. Relief was confined to the peculiar facts and declared non-precedential.
Doctrine of merger did not apply where a statutory appeal against GST registration cancellation was summarily dismissed as time-barred; the original cancellation order therefore remained open to challenge under Articles 226 and 227. HC held that dismissal on limitation did not bar writ relief. On the registrant's bona fide explanation for failing to answer the show-cause notice, HC adopted a justice-oriented approach, quashed the cancellation, and directed restoration conditional on timely filing of returns and payment of outstanding tax, interest and penalty. Relief was confined to the peculiar facts and declared non-precedential.
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TaxTMI 
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