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...
Validity of reassessment order u/s 147 - Denial of Cross-Examination Opportunity - Reliance of statement of third party - The High Court noted that the petitioner did not specifically request summons for cross-examination during the assessment proceedings. While acknowledging the importance of natural justice, the Court held that the petitioner's failure to make a specific prayer for cross-examination before the assessing officer precluded the writ petition's consideration on those grounds. The Court highlighted the alternative remedy of appeal and directed the petitioner to approach the appellate authority within 15 days, with the option to request cross-examination of Third Party.
Validity of reassessment order u/s 147 - Denial of Cross-Examination Opportunity - Reliance of statement of third party - The High Court noted that the petitioner did not specifically request summons for cross-examination during the assessment proceedings. While acknowledging the importance of natural justice, the Court held that the petitioner's failure to make a specific prayer for cross-examination before the assessing officer precluded the writ petition's consideration on those grounds. The Court highlighted the alternative remedy of appeal and directed the petitioner to approach the appellate authority within 15 days, with the option to request cross-examination of Third Party.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
