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...
Job-work - benefit of N/N. 214/96 and N/N. 84/95-CE cannot be extended to the appellant as the requisite undertakings have not been given by the appellant - These undertakings are not merely procedural undertaking but substantive undertaking in so far as by virtue of this undertaking, the principal manufacturer takes the responsibility of duty liability in case it arose - AT
Job-work - benefit of N/N. 214/96 and N/N. 84/95-CE cannot be extended to the appellant as the requisite undertakings have not been given by the appellant - These undertakings are not merely procedural undertaking but substantive undertaking in so far as by virtue of this undertaking, the principal manufacturer takes the responsibility of duty liability in case it arose - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
