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...
Principles of natural justice violated due to non-uploading of show cause notice (SCN) u/s 73 on portal's "view notices and orders" section. Despite email communications informing petitioner about SCN's location, confusion persisted due to portal redesign. Petitioner permitted to challenge adjudication order before appellate authority within 30 days by filing appeal with condonation application. Appellate authority directed to condone delay, hear appeal on merits, pass reasoned order within 12 weeks after hearing petitioner, subject to pre-deposit compliance u/s 107.
Principles of natural justice violated due to non-uploading of show cause notice (SCN) u/s 73 on portal's "view notices and orders" section. Despite email communications informing petitioner about SCN's location, confusion persisted due to portal redesign. Petitioner permitted to challenge adjudication order before appellate authority within 30 days by filing appeal with condonation application. Appellate authority directed to condone delay, hear appeal on merits, pass reasoned order within 12 weeks after hearing petitioner, subject to pre-deposit compliance u/s 107.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
