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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Seeking conversion of shipping bills - The appellant has established its bona fides; but for the inaction by the DGFT, perhaps there would not have been any delay in seeking conversion/ amendment under Section 149 ibid. Vide letter dated 21.01.2016 itself the appellant did communicate to the DGFT for issuance of EODC by contending that it had fulfilled the export obligation, in response to which the said authority had replied on 25.01.2016 asking for bank realization certificates and, if at all there were any deficiencies, nothing prevented the said authority from communicating the same to the appellant-exporter. - Conversion allowed - AT
Seeking conversion of shipping bills - The appellant has established its bona fides; but for the inaction by the DGFT, perhaps there would not have been any delay in seeking conversion/ amendment under Section 149 ibid. Vide letter dated 21.01.2016 itself the appellant did communicate to the DGFT for issuance of EODC by contending that it had fulfilled the export obligation, in response to which the said authority had replied on 25.01.2016 asking for bank realization certificates and, if at all there were any deficiencies, nothing prevented the said authority from communicating the same to the appellant-exporter. - Conversion allowed - AT
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