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...
Non-application of mind in passing orders regarding carry forward of Input Tax Credit, resulting in violation of principles of natural justice. Orders quashed due to contradictory statements about personal hearing granted or not. Proper Officer directed to re-adjudicate Show Cause Notices after considering petitioner's reply and contentions that input tax credit was carried forward to next year without utilization in the same year.
Non-application of mind in passing orders regarding carry forward of Input Tax Credit, resulting in violation of principles of natural justice. Orders quashed due to contradictory statements about personal hearing granted or not. Proper Officer directed to re-adjudicate Show Cause Notices after considering petitioner's reply and contentions that input tax credit was carried forward to next year without utilization in the same year.
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