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 - Sanction for issue of notice u/s 151 - The High Court found that the AO had acted based on borrowed satisfaction and lacked independent application of mind. Additionally, the court ruled that the approval granted was merely mechanical and did not involve proper consideration. Consequently, the court upheld the decision of the ITAT to quash the reopening proceedings and notice issued under Section 148 of the Act, dismissing the appeal of the Revenue.
Validity of reopening of assessment - Sanction for issue of notice u/s 151 - The High Court found that the AO had acted based on borrowed satisfaction and lacked independent application of mind. Additionally, the court ruled that the approval granted was merely mechanical and did not involve proper consideration. Consequently, the court upheld the decision of the ITAT to quash the reopening proceedings and notice issued under Section 148 of the Act, dismissing the appeal of the Revenue.
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TaxTMI 
TaxTMI 
of 4886 
