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...
The High Court accepted the petitioner's contention that they were prevented from filing an appeal within the stipulated time due to the delay in communicating the impugned order. Despite the provision stating that the limitation period commences from the date of passing the order, the court held that since there is a provision for filing an appeal, it necessarily implies that the factual aspects shall be examined by the Appellate Authority. Consequently, the petition was disposed of, allowing the petitioner to file an appeal against the impugned order within the prescribed time limit from the date of receiving the order's communication.
The High Court accepted the petitioner's contention that they were prevented from filing an appeal within the stipulated time due to the delay in communicating the impugned order. Despite the provision stating that the limitation period commences from the date of passing the order, the court held that since there is a provision for filing an appeal, it necessarily implies that the factual aspects shall be examined by the Appellate Authority. Consequently, the petition was disposed of, allowing the petitioner to file an appeal against the impugned order within the prescribed time limit from the date of receiving the order's communication.
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TaxTMI 
TaxTMI 
of 4879 
