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...
Extended period of Limitation - There is no obligation cast on the appellant to intimate the Department on each and every transaction. The appellant have filed regular returns with the Department and have maintained proper records. Further, the appellant have obtained statement of “cost of production‟ duly certified by the Cost Accountant - The elements of suppression, mis-statement, fraud, etc. are not coming out from the facts and circumstances.
Extended period of Limitation - There is no obligation cast on the appellant to intimate the Department on each and every transaction. The appellant have filed regular returns with the Department and have maintained proper records. Further, the appellant have obtained statement of “cost of production‟ duly certified by the Cost Accountant - The elements of suppression, mis-statement, fraud, etc. are not coming out from the facts and circumstances.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
