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...
Reopening of assessment - Validity of order u/s 147 r.w.s 144 - Faceless assessment u/s 144B - No doubt there is a failure on the part of the petitioner to have complied with the requirements of Section 176 of the Income Tax Act, 1961 after partnership firm purportedly ceased to exist and discontinued with the business. There is also a failure on the part of the petitioner to give in the details of the account Nos. of the partnership firm while responding to the show cause notice issued u/s 147 - However, the impugned order is bereft of details. - Matter restored back - HC
Reopening of assessment - Validity of order u/s 147 r.w.s 144 - Faceless assessment u/s 144B - No doubt there is a failure on the part of the petitioner to have complied with the requirements of Section 176 of the Income Tax Act, 1961 after partnership firm purportedly ceased to exist and discontinued with the business. There is also a failure on the part of the petitioner to give in the details of the account Nos. of the partnership firm while responding to the show cause notice issued u/s 147 - However, the impugned order is bereft of details. - Matter restored back - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
