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...
Transfer of Un-utilised cenvat credit balance - amalgamation - Since the effective date of the transfer is 01.06.2005, which has been specifically mentioned in the order dated 09.10.2006 of the Hon’ble Delhi High Court, there is no scope of transfer of any cenvat credit balance lying in the cenvat credit account of M/s. M/s. Karamchand Appliances Pvt. Ltd. to the appellant prior to such date. - AT
Transfer of Un-utilised cenvat credit balance - amalgamation - Since the effective date of the transfer is 01.06.2005, which has been specifically mentioned in the order dated 09.10.2006 of the Hon’ble Delhi High Court, there is no scope of transfer of any cenvat credit balance lying in the cenvat credit account of M/s. M/s. Karamchand Appliances Pvt. Ltd. to the appellant prior to such date. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
