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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Rejection of Petitioners’ application for amendment of the shipping bills - Section 149 of the Customs Act - the Assistant Commissioner could not have been oblivious of the settled position in law that once the Gujarat High Court had struck down the Circular considering that the Customs Act has a pan-India operation being a Central Act - The decision of the Gujarat High Court on the Circular in question was applicable and binding on all the customs jurisdictions throughout India. - HC
Rejection of Petitioners’ application for amendment of the shipping bills - Section 149 of the Customs Act - the Assistant Commissioner could not have been oblivious of the settled position in law that once the Gujarat High Court had struck down the Circular considering that the Customs Act has a pan-India operation being a Central Act - The decision of the Gujarat High Court on the Circular in question was applicable and binding on all the customs jurisdictions throughout India. - HC
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