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...
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Transfer of case u/s 127 - centralization of case after search - delayed challenge to the order passed u/s 153A - the impugned order came to be passed on 19.02.2019 and till the issuance of the assessment notices dated 15.07.2019 under Section 153A of the Act, the petitioner did not challenge the order of transfer and there is no explanation for the delay in challenge. Hence, the petitioner is barred from challenging the same in exercise of jurisdiction by a new authority - HC
Transfer of case u/s 127 - centralization of case after search - delayed challenge to the order passed u/s 153A - the impugned order came to be passed on 19.02.2019 and till the issuance of the assessment notices dated 15.07.2019 under Section 153A of the Act, the petitioner did not challenge the order of transfer and there is no explanation for the delay in challenge. Hence, the petitioner is barred from challenging the same in exercise of jurisdiction by a new authority - HC
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