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 - rejection on the ground that the invoice of service is not in the name of the appellant whereas the same is in the name of CHA - in the service provider’s invoice that is issued by M/s Indev Logistics Pvt. Ltd. the name of appellant is appearing as shipper name and in the corresponding invoice of the 4 Star Enterprises which is the appellant’s CHA is showing the exact amount of M/s Indev Logistics Pvt. Ltd. therefore the proper co-relation has been established. - Refund allowed - AT
Refund claim - rejection on the ground that the invoice of service is not in the name of the appellant whereas the same is in the name of CHA - in the service provider’s invoice that is issued by M/s Indev Logistics Pvt. Ltd. the name of appellant is appearing as shipper name and in the corresponding invoice of the 4 Star Enterprises which is the appellant’s CHA is showing the exact amount of M/s Indev Logistics Pvt. Ltd. therefore the proper co-relation has been established. - Refund allowed - AT
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