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...
Recovery of arrears of tax - When the Hon'ble Supreme Court has held that taxes paid by the assessee/appellant will not be refunded, it does not allow the Department to collect the differential taxes in the case of assessees who have not met the demands already made - It is trite that even though all statutory remedies are exhausted and held against the petitioner, it is legal to invoke powers under Article 226 to challenge the same as it vitiates the old law. - HC
Recovery of arrears of tax - When the Hon'ble Supreme Court has held that taxes paid by the assessee/appellant will not be refunded, it does not allow the Department to collect the differential taxes in the case of assessees who have not met the demands already made - It is trite that even though all statutory remedies are exhausted and held against the petitioner, it is legal to invoke powers under Article 226 to challenge the same as it vitiates the old law. - HC
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TaxTMI 
TaxTMI 
of 4894 
