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...
Maintainability of petition before the High Court - availability of alternative remedy of statutory appeal - total lack of jurisdiction on the part of the Assessing Officer in passing the O-I-O or not - As such it cannot be said that there was total lack of jurisdiction on the part of the Assessing Officer in passing the O-I-O. Despite the above the High Court has entertained the writ petition under Article 226 of the Constitution of India and has entered into the merits of the case though the original writ petitioner did not avail the alternative statutory remedy of appeal against the order of O-I-O. - The impugned judgment and order passed by the High Court is hereby quashed and set aside - SC
Maintainability of petition before the High Court - availability of alternative remedy of statutory appeal - total lack of jurisdiction on the part of the Assessing Officer in passing the O-I-O or not - As such it cannot be said that there was total lack of jurisdiction on the part of the Assessing Officer in passing the O-I-O. Despite the above the High Court has entertained the writ petition under Article 226 of the Constitution of India and has entered into the merits of the case though the original writ petitioner did not avail the alternative statutory remedy of appeal against the order of O-I-O. - The impugned judgment and order passed by the High Court is hereby quashed and set aside - SC
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TaxTMI 
TaxTMI 
of 4886 
