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...
Levy of penalty - no E-Way Bill, invoice and bilty were present in the vehicle carrying the goods - onus to prove (shifting burden) - The High court held that the petitioner failed to rebut the presumption of tax evasion since they could not explain the absence of the invoice and E-Way Bill. Thus, the penalty imposed is upheld, emphasizing that penalties act as deterrents to tax evasion.
Levy of penalty - no E-Way Bill, invoice and bilty were present in the vehicle carrying the goods - onus to prove (shifting burden) - The High court held that the petitioner failed to rebut the presumption of tax evasion since they could not explain the absence of the invoice and E-Way Bill. Thus, the penalty imposed is upheld, emphasizing that penalties act as deterrents to tax evasion.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
