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...
Levy of Penalty u/s 112 (a) of the Customs Act on the employees of CHA - The appellant was working as per the instructions given to him by his senior. There is no case made out of any abnormal gain by the appellant to indicate any collusion or abetment on his part with the importer of the consignment under dispute - Penalty has been imposed mechanically without application of mind - AT
Levy of Penalty u/s 112 (a) of the Customs Act on the employees of CHA - The appellant was working as per the instructions given to him by his senior. There is no case made out of any abnormal gain by the appellant to indicate any collusion or abetment on his part with the importer of the consignment under dispute - Penalty has been imposed mechanically without application of mind - AT
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