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...
Alternative remedy of appeal - writ jurisdiction will be exercised only in cases of certain specific exceptions and particularly (a) lack of jurisdiction, (b) violation of 'natural justice principles' or it should be a case of alternate remedy being ineffectual or not efficacious - It is certainly nobody's case an appeal to the Commissioner (Appeals) is either ineffectual or not efficacious - writ dismissed
Alternative remedy of appeal - writ jurisdiction will be exercised only in cases of certain specific exceptions and particularly (a) lack of jurisdiction, (b) violation of 'natural justice principles' or it should be a case of alternate remedy being ineffectual or not efficacious - It is certainly nobody's case an appeal to the Commissioner (Appeals) is either ineffectual or not efficacious - writ dismissed
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TaxTMI 
TaxTMI 
of 4883 
