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...
Demanded of interest for the delayed payment of education cess - Education cess and secondary and higher education cess should not be included in the aggregate value for duties on DTA (Domestic Tariff Area) clearances by 100% EOUs (Export Oriented Units). The decision emphasized the principle of not charging a cess on the same tax base more than once, adhering to judicial discipline and the precedential value of the Larger Bench's ruling. - Demand set aside - AT
Demanded of interest for the delayed payment of education cess - Education cess and secondary and higher education cess should not be included in the aggregate value for duties on DTA (Domestic Tariff Area) clearances by 100% EOUs (Export Oriented Units). The decision emphasized the principle of not charging a cess on the same tax base more than once, adhering to judicial discipline and the precedential value of the Larger Bench's ruling. - Demand set aside - AT
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