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...
Revised Form-3 certificates correcting computational errors cannot impose a payment deadline that expired before the revised certificate was issued, because this would require impossible performance. Payment of the revised quantified amount and intimation on the day after issuance complied with the requirement to pay within 15 days of receiving the certificate. The demand notice and interest order were set aside, and the declarant became entitled to statutory acknowledgment of payment and issuance of Form-5 for closure under the Direct Tax Vivad se Vishwas Scheme.
Revised Form-3 certificates correcting computational errors cannot impose a payment deadline that expired before the revised certificate was issued, because this would require impossible performance. Payment of the revised quantified amount and intimation on the day after issuance complied with the requirement to pay within 15 days of receiving the certificate. The demand notice and interest order were set aside, and the declarant became entitled to statutory acknowledgment of payment and issuance of Form-5 for closure under the Direct Tax Vivad se Vishwas Scheme.
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TaxTMI 
TaxTMI 
of 4896 
