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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Empowerment to deny availment of exemption extended to indigenously manufactured goods - The essence of optimal sourcing being the disregarding of customs frontiers, the enumeration of goods entitled to exemption from duties of customs does not bear replication in the exemption notification under Central Excise Act, 1944 and the condition prescribed therein should not have to be expanded beyond that limited purpose. It would be stating the obvious to point out that domestic procurement is not subject to the same risks or the verification of eligibility so burdensome as to warrant that the facilitative procedures of the notification issued under Customs Act, 1962 be replicated in the notification issued under Central Excise Act, 1944. - AT
Empowerment to deny availment of exemption extended to indigenously manufactured goods - The essence of optimal sourcing being the disregarding of customs frontiers, the enumeration of goods entitled to exemption from duties of customs does not bear replication in the exemption notification under Central Excise Act, 1944 and the condition prescribed therein should not have to be expanded beyond that limited purpose. It would be stating the obvious to point out that domestic procurement is not subject to the same risks or the verification of eligibility so burdensome as to warrant that the facilitative procedures of the notification issued under Customs Act, 1962 be replicated in the notification issued under Central Excise Act, 1944. - AT
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