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...
Refund claim - tax liability discharged by the appellant twice - The verification report of the department itself is supporting the appellant’s contention that the same liability has been discharged twice by the appellant once inadvertently in the inactive account, subsequently, in the active account - no other evidence was required to be produced by the appellant. Otherwise also it is a settled law that onus always rests upon the department to prove the allegations raised in the show cause notice - Refund allowed - AT
Refund claim - tax liability discharged by the appellant twice - The verification report of the department itself is supporting the appellant’s contention that the same liability has been discharged twice by the appellant once inadvertently in the inactive account, subsequently, in the active account - no other evidence was required to be produced by the appellant. Otherwise also it is a settled law that onus always rests upon the department to prove the allegations raised in the show cause notice - Refund allowed - AT
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