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...
Demand of service tax under mining service and supply of tangible goods for use categories is unsustainable as sizing of stones/boulders amounts to manufacture. Effective control and possession of equipment was transferred to recipient. Revenue authorities were aware of appellants' activities, hence no suppression or wilful misstatement. Appeals allowed on merits and limitation grounds.
Demand of service tax under mining service and supply of tangible goods for use categories is unsustainable as sizing of stones/boulders amounts to manufacture. Effective control and possession of equipment was transferred to recipient. Revenue authorities were aware of appellants' activities, hence no suppression or wilful misstatement. Appeals allowed on merits and limitation grounds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
