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...
Impugned order partially upheld, petitioner directed to pay balance tax demand without prejudice to rights under remand order; petitioner also required to pay interest amount; respondents directed to pass fresh orders on merits regarding penalty u/s 122 of GST Act within six months, penalty may be dropped if 53rd GST Council recommendations implemented; petition disposed of.
Impugned order partially upheld, petitioner directed to pay balance tax demand without prejudice to rights under remand order; petitioner also required to pay interest amount; respondents directed to pass fresh orders on merits regarding penalty u/s 122 of GST Act within six months, penalty may be dropped if 53rd GST Council recommendations implemented; petition disposed of.
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TaxTMI 
TaxTMI 
of 4879 
