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...
Classification of services - Merely by resorting to what they felt and what they were recovering as ‘Terminal storage charges’ would not make this Appellant also a warehouse keeper. The scope of the service has to be determined in terms of express wordings of that classification in Finance Act & Rules, and not in terms of nomenclature used for collecting the revenue for the services provided to the service recipients - AT
Classification of services - Merely by resorting to what they felt and what they were recovering as ‘Terminal storage charges’ would not make this Appellant also a warehouse keeper. The scope of the service has to be determined in terms of express wordings of that classification in Finance Act & Rules, and not in terms of nomenclature used for collecting the revenue for the services provided to the service recipients - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
