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...
Refund claim of tax wrongly paid or allowing ITC to the correct party - inadvertent mistake in filling the GST number in the GSTR-1 - seeking permission to rectify the details of the recipient of the service in the form of GSTR-1 - Difficulty in following the Circular as the GST portal did not permit to rectify the defects - As the Circular of the year 2019 restricts only electronic filing and as the contention of the respondents that the claim of the petitioner is barred by limitation is not acceptable, the respondents cannot retain the amount, which was paid by the petitioner. - HC
Refund claim of tax wrongly paid or allowing ITC to the correct party - inadvertent mistake in filling the GST number in the GSTR-1 - seeking permission to rectify the details of the recipient of the service in the form of GSTR-1 - Difficulty in following the Circular as the GST portal did not permit to rectify the defects - As the Circular of the year 2019 restricts only electronic filing and as the contention of the respondents that the claim of the petitioner is barred by limitation is not acceptable, the respondents cannot retain the amount, which was paid by the petitioner. - HC
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