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...
Levy of penalty at reduced rate - the appellant being a small operator had no wherewithal to keep track of the law and thus, the applicability of the Service Tax to him - Looking into the conduct of the appellants in depositing the tax with interest and 25% penalty the provisions of Section 80 are invited and the benefits of Section 80 can be extended to the appellants. - AT
Levy of penalty at reduced rate - the appellant being a small operator had no wherewithal to keep track of the law and thus, the applicability of the Service Tax to him - Looking into the conduct of the appellants in depositing the tax with interest and 25% penalty the provisions of Section 80 are invited and the benefits of Section 80 can be extended to the appellants. - AT
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