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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Levy of penalty under Rule 12 (6) of Central Excise Rules - late filing of Returns (ER-1) for the period July, 2017 to February, 2018 - There is no saving Clause in the said Section, for initiating and imposing penalty for none filing of the returns (ER-1), once the provisions of GST have been imposed w.e.f. 1st July, 2017. Accordingly, the show cause notice in misconceived and the impugned order have been erroneously passed, having no sanctity in law. - AT
Levy of penalty under Rule 12 (6) of Central Excise Rules - late filing of Returns (ER-1) for the period July, 2017 to February, 2018 - There is no saving Clause in the said Section, for initiating and imposing penalty for none filing of the returns (ER-1), once the provisions of GST have been imposed w.e.f. 1st July, 2017. Accordingly, the show cause notice in misconceived and the impugned order have been erroneously passed, having no sanctity in law. - AT
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