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...
Applicability of interest to CENVAT credit recovery - Availed versus Taken and / or utilization of credit - Recovery of CENVAT credit wrongly taken or erroneously refunded - it is unusual for ‘utilization’ to be qualified with ‘ineligibility’ on its own as ‘utilization’ is solely for the purpose of discharge of tax/duty liability which, even if not warranted, does not, by any stretch of usage, behove description as ‘wrongly.’ Such a transferred epithet can only reasonably mean ‘utilization’ after having been wrongly taken and, thereby, made ineligible. - AT
Applicability of interest to CENVAT credit recovery - Availed versus Taken and / or utilization of credit - Recovery of CENVAT credit wrongly taken or erroneously refunded - it is unusual for ‘utilization’ to be qualified with ‘ineligibility’ on its own as ‘utilization’ is solely for the purpose of discharge of tax/duty liability which, even if not warranted, does not, by any stretch of usage, behove description as ‘wrongly.’ Such a transferred epithet can only reasonably mean ‘utilization’ after having been wrongly taken and, thereby, made ineligible. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
