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...
Power of Central Government u/s 85 & 86 - Black Money Act, 2015 - ultravirus of notifications issued making them effective prior to 01.04.2016 - A fortiori the Central Government further could not have, prior to the said Act coming into force i.e. 01.04.2016, altered the date by exercising the powers available to it u/ss 85 and 86 by advancing it to 01.07.2015 - a good prima facie case for grant of interim relief
Power of Central Government u/s 85 & 86 - Black Money Act, 2015 - ultravirus of notifications issued making them effective prior to 01.04.2016 - A fortiori the Central Government further could not have, prior to the said Act coming into force i.e. 01.04.2016, altered the date by exercising the powers available to it u/ss 85 and 86 by advancing it to 01.07.2015 - a good prima facie case for grant of interim relief
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