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...
GTA Service - denial of benefit of 75% abatement in the absence of any declaration furnished by the transport agencies - There is no merit in the submissions that even without declaration as stipulated in the notification, the assessee was entitled to such exemption, is over simplifying or glossing over the conditions itself, which cannot be permitted. - Tribunal was perfectly justified in denying such exemption.
GTA Service - denial of benefit of 75% abatement in the absence of any declaration furnished by the transport agencies - There is no merit in the submissions that even without declaration as stipulated in the notification, the assessee was entitled to such exemption, is over simplifying or glossing over the conditions itself, which cannot be permitted. - Tribunal was perfectly justified in denying such exemption.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
