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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Guidelines clarify recovery proceedings in cases where first appeal is disposed but taxpayer cannot file further appeal due to non-operation of Appellate Tribunal. Taxpayers can make pre-deposit payment through Electronic Liability Register to avail stay on recovery. Undertaking to file appeal when Tribunal operationalizes is required. Amounts paid inadvertently through DRC-03 can be adjusted towards pre-deposit by filing DRC-03A application. Till DRC-03A functionality is available, intimation to proper officer suffices for stay on recovery. Failure to file appeal after Tribunal's operation will lead to recovery as per law.
Guidelines clarify recovery proceedings in cases where first appeal is disposed but taxpayer cannot file further appeal due to non-operation of Appellate Tribunal. Taxpayers can make pre-deposit payment through Electronic Liability Register to avail stay on recovery. Undertaking to file appeal when Tribunal operationalizes is required. Amounts paid inadvertently through DRC-03 can be adjusted towards pre-deposit by filing DRC-03A application. Till DRC-03A functionality is available, intimation to proper officer suffices for stay on recovery. Failure to file appeal after Tribunal's operation will lead to recovery as per law.
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