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...
Revision petitions filed within time limit granted by High Court, rejecting them on ground of limitation without hearing petitioner violates natural justice. Impugned orders rejecting revision petitions solely on limitation ground illegal, liable to be set aside. Petition allowed.
Revision petitions filed within time limit granted by High Court, rejecting them on ground of limitation without hearing petitioner violates natural justice. Impugned orders rejecting revision petitions solely on limitation ground illegal, liable to be set aside. Petition allowed.
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