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...
Confiscation - absence of the BIS stickers on the Cold Rolled Non-Grain Oriented Silicon Steel Sheet in Coil - the bona fide of the appellant is evident on the face of the record as they offered to re-export the goods, on the clearance being object to for domestic consumption - There is no deliberate breach of the quality control order and for the venial breach the provisions of confiscation and penalty are not attracted - AT
Confiscation - absence of the BIS stickers on the Cold Rolled Non-Grain Oriented Silicon Steel Sheet in Coil - the bona fide of the appellant is evident on the face of the record as they offered to re-export the goods, on the clearance being object to for domestic consumption - There is no deliberate breach of the quality control order and for the venial breach the provisions of confiscation and penalty are not attracted - AT
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