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...
Cenvat credit on immovable property constructed after issuance of completion certificate is not permissible, as transaction is treated as sale of goods, not service. Cenvat credit can be taken only on receipt of inputs and within one year from date of documents. Extended period of limitation rightly invoked as appellant was aware of ineligibility for credit after completion certificate. Imposition of penalty u/s 78 and levy of interest upheld. Appeal dismissed by Appellate Tribunal.
Cenvat credit on immovable property constructed after issuance of completion certificate is not permissible, as transaction is treated as sale of goods, not service. Cenvat credit can be taken only on receipt of inputs and within one year from date of documents. Extended period of limitation rightly invoked as appellant was aware of ineligibility for credit after completion certificate. Imposition of penalty u/s 78 and levy of interest upheld. Appeal dismissed by Appellate Tribunal.
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TaxTMI 
TaxTMI 
of 4879 
