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...
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Condonation of delay of 2 years and 300 days in filing a Tax Revision Application - After several adjournments, the applicant has stated that they are not in a position even to secure the tax or part. Though this is not a consideration for either condoning or not condoning the delay, we think that the entire conduct of the applicant does suggest that the applicant was far from diligent and the proceedings were taken up only to delay or avoid the payment of the tax as determined. The Applicant perhaps carried the impression that the mere pendency of proceedings might delay the action from the tax authorities and took full advantage of this impression to delay the proceedings. - Application dismissed - HC
Condonation of delay of 2 years and 300 days in filing a Tax Revision Application - After several adjournments, the applicant has stated that they are not in a position even to secure the tax or part. Though this is not a consideration for either condoning or not condoning the delay, we think that the entire conduct of the applicant does suggest that the applicant was far from diligent and the proceedings were taken up only to delay or avoid the payment of the tax as determined. The Applicant perhaps carried the impression that the mere pendency of proceedings might delay the action from the tax authorities and took full advantage of this impression to delay the proceedings. - Application dismissed - HC
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