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...
Stay of demand - if the assessee makes a request to grant an absolute stay, the ITAT has to apply its mind to all the possible avenues that are available for the dispensation of justice and If absolute stay is not possible, parameters of conditional stay has to be examined and an appropriate decision has to be taken in the circumstances of the case - a cryptic order passed by the ITAT without assigning valid reasons is not sustainable
Stay of demand - if the assessee makes a request to grant an absolute stay, the ITAT has to apply its mind to all the possible avenues that are available for the dispensation of justice and If absolute stay is not possible, parameters of conditional stay has to be examined and an appropriate decision has to be taken in the circumstances of the case - a cryptic order passed by the ITAT without assigning valid reasons is not sustainable
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
