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...
The High Court addressed a case where Budgetary support was claimed by Bagheri Unit, not Baga Unit. The court found that the petitioner's plea for full budgetary support for Bagheri Unit was not considered. Orders by the 4th respondent and Commissioner (Appeals) were set aside. The matter was remitted back to the 4th respondent for fresh decision after providing a personal hearing. The 4th respondent's failure to give a personal hearing and provide reasons for rejecting a portion of the claim led to setting aside of the Order-in-Original. The case was remanded back for reconsideration of the claim for budgetary support for the 3rd quarter. The petition was disposed of through remand.
The High Court addressed a case where Budgetary support was claimed by Bagheri Unit, not Baga Unit. The court found that the petitioner's plea for full budgetary support for Bagheri Unit was not considered. Orders by the 4th respondent and Commissioner (Appeals) were set aside. The matter was remitted back to the 4th respondent for fresh decision after providing a personal hearing. The 4th respondent's failure to give a personal hearing and provide reasons for rejecting a portion of the claim led to setting aside of the Order-in-Original. The case was remanded back for reconsideration of the claim for budgetary support for the 3rd quarter. The petition was disposed of through remand.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
