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...
Right to obtain copies of statements recorded u/s 108 of CA - The statements cannot be termed as documents produced in or in the custody of the court, copies of which are liable to be issued under Rule 222 - Hence, discretion is vested with the court to refuse copies, if the documents or proceedings are confidential or strictly judicial in nature. The learned Magistrate having refused to issue copies of the Section 108 statements finding them to be confidential, there are no reason to interfere with the impugned order. - HC
Right to obtain copies of statements recorded u/s 108 of CA - The statements cannot be termed as documents produced in or in the custody of the court, copies of which are liable to be issued under Rule 222 - Hence, discretion is vested with the court to refuse copies, if the documents or proceedings are confidential or strictly judicial in nature. The learned Magistrate having refused to issue copies of the Section 108 statements finding them to be confidential, there are no reason to interfere with the impugned order. - HC
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