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...
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Revisional jurisdiction u/s 264 - Application u/s 264 rejected as intimation u/s 143(1) of the Act is not an order amenable to revisional jurisdiction u/s 264 - The court ruled that intimation under Section 143(1) is amenable to revisional jurisdiction under Section 264 of the Act. This was based on precedent in "Diwaker Tripathi v. Principal Commissioner of Income tax – 17 & Ors.", which allowed for such revision.
Revisional jurisdiction u/s 264 - Application u/s 264 rejected as intimation u/s 143(1) of the Act is not an order amenable to revisional jurisdiction u/s 264 - The court ruled that intimation under Section 143(1) is amenable to revisional jurisdiction under Section 264 of the Act. This was based on precedent in "Diwaker Tripathi v. Principal Commissioner of Income tax – 17 & Ors.", which allowed for such revision.
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