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...
Levy of penalty u/s 112(a) of the Customs Act, 1962 on the Customs Broker - Section 112 ibid. does not contemplate penal action for violations of provisions or regulations under any other law, much less violation under the CBLR; the charge is very specific: the act or omission should result in improper import of goods and consequently, confiscation of such goods, which is not the case of the Revenue here in the case on hand. - No penalty - AT
Levy of penalty u/s 112(a) of the Customs Act, 1962 on the Customs Broker - Section 112 ibid. does not contemplate penal action for violations of provisions or regulations under any other law, much less violation under the CBLR; the charge is very specific: the act or omission should result in improper import of goods and consequently, confiscation of such goods, which is not the case of the Revenue here in the case on hand. - No penalty - AT
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