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...
Insolvency and BankruptcyJanuary 25, 2022Case LawsHC
Fresh demand of income tax after the Approval of Resolution Plan - Demand of Income Tax Dues after completion of scrutiny process - From the tone and tenor of the impugned notices what is evident is that respondents are seeking to pass assessment order under Section 143 (3) of the Act since the case of petitioner No.1 was selected for limited scrutiny under CASS. However, the period of the assessment order would be a period covered by the resolution plan - the claim of the Income Tax Department which is outside the resolution plan would stand extinguished. - HC
Fresh demand of income tax after the Approval of Resolution Plan - Demand of Income Tax Dues after completion of scrutiny process - From the tone and tenor of the impugned notices what is evident is that respondents are seeking to pass assessment order under Section 143 (3) of the Act since the case of petitioner No.1 was selected for limited scrutiny under CASS. However, the period of the assessment order would be a period covered by the resolution plan - the claim of the Income Tax Department which is outside the resolution plan would stand extinguished. - HC
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