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...
Violation of principles of natural justice alleged due to notice being served under incorrect tab on online portal. Court found notice was uploaded, though under "additional notices" tab instead of "view notices and orders" tab. Controversy regarding adequacy of service by uploading under "additional notices" tab not decided. Petitioner directed to avail alternate remedy of appeal before appellate authority within 30 days, as appeal available against order. Petition disposed.
Violation of principles of natural justice alleged due to notice being served under incorrect tab on online portal. Court found notice was uploaded, though under "additional notices" tab instead of "view notices and orders" tab. Controversy regarding adequacy of service by uploading under "additional notices" tab not decided. Petitioner directed to avail alternate remedy of appeal before appellate authority within 30 days, as appeal available against order. Petition disposed.
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