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...
Denial of refund claim - Unjust enrichment - There is no prohibition/restriction in section 11B of the Act that credit note cannot be issued at a later date than the date of supply of the goods. In absence of any prohibition in the statute, denial of refund benefit to the appellant is contrary to the statutory mandates. - AT
Denial of refund claim - Unjust enrichment - There is no prohibition/restriction in section 11B of the Act that credit note cannot be issued at a later date than the date of supply of the goods. In absence of any prohibition in the statute, denial of refund benefit to the appellant is contrary to the statutory mandates. - AT
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