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...
Validity of reopening of assessment - period of limitation to issue notice - validity of a notice issued under Section 148/148A - scope of Taxation and other laws (Relaxation and Amendment of certain provisions) Act, 2020 (TOLA) application - The High Court refers to a previous judgment and concludes that the notices issued for the Assessment Year 2013-2014 are barred by limitation due to the amendments to the Finance Act and the provisions existing prior to the amendment. - The Court specifically addresses various contentions raised by the Department regarding the applicability of different legal provisions and notifications, ultimately ruling in favor of the petitioners.
Validity of reopening of assessment - period of limitation to issue notice - validity of a notice issued under Section 148/148A - scope of Taxation and other laws (Relaxation and Amendment of certain provisions) Act, 2020 (TOLA) application - The High Court refers to a previous judgment and concludes that the notices issued for the Assessment Year 2013-2014 are barred by limitation due to the amendments to the Finance Act and the provisions existing prior to the amendment. - The Court specifically addresses various contentions raised by the Department regarding the applicability of different legal provisions and notifications, ultimately ruling in favor of the petitioners.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
