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 SCN - SCN not communicating the relevant information and material thereby disabling the petitioner to respond to the same - Since the Statute itself prescribes for affording reasonable opportunity, it is incumbent upon the Revenue to afford the same and any deficiency in that regard vitiates the end result. - the show cause notice are quashed with a liberty to the competent authority to proceed in the matter in accordance with law, if so advised. - HC
Validity of SCN - SCN not communicating the relevant information and material thereby disabling the petitioner to respond to the same - Since the Statute itself prescribes for affording reasonable opportunity, it is incumbent upon the Revenue to afford the same and any deficiency in that regard vitiates the end result. - the show cause notice are quashed with a liberty to the competent authority to proceed in the matter in accordance with law, if so advised. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
