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...
Reversal/ Refund of the input tax credit - Principles of Estoppel / principle of res judicata - withdrawal of earlier petition - The High court examines the previous withdrawal of the petition and notes that it was unconditional, with no liberty granted to the petitioner. Additionally, the investigation found the petitioner culpable, leading to a show cause notice being issued. - Referring to relevant legal precedents, the court emphasizes the importance of discouraging bench-hunting tactics and upholding public policy to prevent litigants from withdrawing petitions simply to file them before a different bench.
Reversal/ Refund of the input tax credit - Principles of Estoppel / principle of res judicata - withdrawal of earlier petition - The High court examines the previous withdrawal of the petition and notes that it was unconditional, with no liberty granted to the petitioner. Additionally, the investigation found the petitioner culpable, leading to a show cause notice being issued. - Referring to relevant legal precedents, the court emphasizes the importance of discouraging bench-hunting tactics and upholding public policy to prevent litigants from withdrawing petitions simply to file them before a different bench.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
