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 demand of GST raised by State authorities - For the same cause of action, the Central Authority has already initiated action - The petitioner contested the order on the grounds of prior proceedings initiated by the Central Authority and alleged lack of timely information provided to the State authorities. The Court found merit in the petitioner's argument regarding the invalidity of the Demand Order due to prior proceedings and dismissed the State authorities' claims of lack of information. Additionally, the Court rejected reliance on a circular mandate as sufficient justification for the State authorities' actions. Consequently, the High Court set aside/quashed the impugned Demand Order.
Validity of demand of GST raised by State authorities - For the same cause of action, the Central Authority has already initiated action - The petitioner contested the order on the grounds of prior proceedings initiated by the Central Authority and alleged lack of timely information provided to the State authorities. The Court found merit in the petitioner's argument regarding the invalidity of the Demand Order due to prior proceedings and dismissed the State authorities' claims of lack of information. Additionally, the Court rejected reliance on a circular mandate as sufficient justification for the State authorities' actions. Consequently, the High Court set aside/quashed the impugned Demand Order.
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TaxTMI 
TaxTMI 
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