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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Validity of reopening of assessment - notice u/s 148 against petitioner company after the approval of the resolution plan for a period prior to closing - liability of previous management - Citing legal precedents and provisions of the Insolvency and Bankruptcy Code, the High court concluded that once a resolution plan is approved, all dues including statutory dues stand extinguished, and proceedings in respect of such dues cannot be continued. - The court clarified that Section 148 of the Income-tax Act pertains to the assessment of escaped income and cannot be used for purposes beyond its scope, such as collecting evidence against third parties.
Validity of reopening of assessment - notice u/s 148 against petitioner company after the approval of the resolution plan for a period prior to closing - liability of previous management - Citing legal precedents and provisions of the Insolvency and Bankruptcy Code, the High court concluded that once a resolution plan is approved, all dues including statutory dues stand extinguished, and proceedings in respect of such dues cannot be continued. - The court clarified that Section 148 of the Income-tax Act pertains to the assessment of escaped income and cannot be used for purposes beyond its scope, such as collecting evidence against third parties.
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