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...
Levy of GST - activity of holding equity capital by the parent Company in the Petitioner - ultravires Section 5 of the IGST Act, 2017 read with Section 7 of the CGST Act, 2017 or not - The High Court concluded that mere holding of shares by a holding company in its subsidiary cannot be classified as a supply of service, as clarified by circulars issued by both the Central and State Governments. The court held that such activity does not fall within the purview of GST. - Given the similarity of the present case to the referenced judgment, the High Court held that the impugned Show Cause Notices were without jurisdiction or authority of law. Consequently, the court quashed the notices issued by the respondent.
Levy of GST - activity of holding equity capital by the parent Company in the Petitioner - ultravires Section 5 of the IGST Act, 2017 read with Section 7 of the CGST Act, 2017 or not - The High Court concluded that mere holding of shares by a holding company in its subsidiary cannot be classified as a supply of service, as clarified by circulars issued by both the Central and State Governments. The court held that such activity does not fall within the purview of GST. - Given the similarity of the present case to the referenced judgment, the High Court held that the impugned Show Cause Notices were without jurisdiction or authority of law. Consequently, the court quashed the notices issued by the respondent.
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TaxTMI 
TaxTMI 
of 4878 
