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...
Validity of order passed u/s 144B - disregarding the stay granted by this court - In the assessment order, the Assessing Officer is referring to a letter stating that the assessee has furnished the Hon’ble High Court’s letter and reproduce the letter. But it is not a letter but an order of the court, which also shows total non application of mind by the Assessing Officer and by referring to an order of this court as letter the Assessing Officer is undermining the authority of this court. At the request of Mr. Pinto we are not issuing notice for contempt against the Assessing Officer but at the same time such gross disobedience cannot be ignored. This order, therefore, has to be quashed and set aside. - HC
Validity of order passed u/s 144B - disregarding the stay granted by this court - In the assessment order, the Assessing Officer is referring to a letter stating that the assessee has furnished the Hon’ble High Court’s letter and reproduce the letter. But it is not a letter but an order of the court, which also shows total non application of mind by the Assessing Officer and by referring to an order of this court as letter the Assessing Officer is undermining the authority of this court. At the request of Mr. Pinto we are not issuing notice for contempt against the Assessing Officer but at the same time such gross disobedience cannot be ignored. This order, therefore, has to be quashed and set aside. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
