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...
Seeking refund of amount illegally and coercively collected by the respondents - entire amount was forcibly recovered - the sixth respondent cannot confirm the rejection of refund only because of the proceedings pending pursuant to the impugned Show Cause Notice but must necessarily consider the petitioner’s grievance in the light of the proposition as enunciated in the above decision and the Instruction and in a time bound manner. - HC
Seeking refund of amount illegally and coercively collected by the respondents - entire amount was forcibly recovered - the sixth respondent cannot confirm the rejection of refund only because of the proceedings pending pursuant to the impugned Show Cause Notice but must necessarily consider the petitioner’s grievance in the light of the proposition as enunciated in the above decision and the Instruction and in a time bound manner. - HC
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