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...
Validity of Show Cause notice - Non adjudication / delayed adjustication of SCN for 11 years - HC quashed to SCN stating that no explanation has been offered in the written statement which can be held to be a plausible explanation for not adjudicating upon the Show Cause Notice within the time prescribed. - SC dismissed the revenue's SLP/appeal.
Validity of Show Cause notice - Non adjudication / delayed adjustication of SCN for 11 years - HC quashed to SCN stating that no explanation has been offered in the written statement which can be held to be a plausible explanation for not adjudicating upon the Show Cause Notice within the time prescribed. - SC dismissed the revenue's SLP/appeal.
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