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...
Method of valuation - section 4 or 4A of CEA - Packaged Drinking Water - MRP based valuation - The CESTAT determined that packaged drinking water should not be classified as "mineral water" for the purpose of valuation under Section 4A. Despite confusion in the notifications, the court emphasized that taxation statutes cannot be interpreted based on presumptions or assumptions. It held that any ambiguity should be interpreted in favor of the assessee. Therefore, the duty demand under Section 4A could not sustain
Method of valuation - section 4 or 4A of CEA - Packaged Drinking Water - MRP based valuation - The CESTAT determined that packaged drinking water should not be classified as "mineral water" for the purpose of valuation under Section 4A. Despite confusion in the notifications, the court emphasized that taxation statutes cannot be interpreted based on presumptions or assumptions. It held that any ambiguity should be interpreted in favor of the assessee. Therefore, the duty demand under Section 4A could not sustain
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TaxTMI 
TaxTMI 
of 4886 
