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...
Violation of principles of natural justice - impugned order does not take into consideration the reply submitted by the petitioner and is a cryptic order - The High court held that the proper officer failed to adequately consider the petitioner's reply on its merits and did not afford the petitioner an opportunity to clarify or provide further details. Consequently, the court set aside the impugned order and remitted the matter to the Proper Officer for re-adjudication, directing the officer to specify the required details/documents within one week.
Violation of principles of natural justice - impugned order does not take into consideration the reply submitted by the petitioner and is a cryptic order - The High court held that the proper officer failed to adequately consider the petitioner's reply on its merits and did not afford the petitioner an opportunity to clarify or provide further details. Consequently, the court set aside the impugned order and remitted the matter to the Proper Officer for re-adjudication, directing the officer to specify the required details/documents within one week.
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TaxTMI 
TaxTMI 
of 4886 
