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...
CENVAT Credit - Bogus firms - fraudulent Cenvat Credit passing chain to facilitate availment of Cenvat Credit without actual manufacture and supply of duty paid goods - validity of statements relied upon - The order under challenge is held to be passed in violation of statutory principles as that of principles of natural justice. The order is also held to be absolutely presumptive having been passed without appreciation of evidence produced by the appellant, but by relying upon the third party evidence - Demand set aside - AT
CENVAT Credit - Bogus firms - fraudulent Cenvat Credit passing chain to facilitate availment of Cenvat Credit without actual manufacture and supply of duty paid goods - validity of statements relied upon - The order under challenge is held to be passed in violation of statutory principles as that of principles of natural justice. The order is also held to be absolutely presumptive having been passed without appreciation of evidence produced by the appellant, but by relying upon the third party evidence - Demand set aside - AT
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