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...
Penalty u/s 271(1)(c) - defective show cause notice - the impugned SCN qualifies as a notice u/s 292B - it cannot be held to be invalid merely by mistake or defect of issuing it in a template and not scoring of the relevant ground and leaving out the applicable ground - Department allowed to issue addendum/ corrigendum/ errata.
Penalty u/s 271(1)(c) - defective show cause notice - the impugned SCN qualifies as a notice u/s 292B - it cannot be held to be invalid merely by mistake or defect of issuing it in a template and not scoring of the relevant ground and leaving out the applicable ground - Department allowed to issue addendum/ corrigendum/ errata.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
