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...
Notice u/s 142(1) was issued to petitioner, but respondent failed to state when it was delivered/served, violating principles of natural justice. Impugned order deserves to be set aside adopting justice-oriented approach, granting petitioner opportunity to reply to Section 142 notice. Respondent entitled to claim interest on demand amount if order passed against petitioner after remand due to lapse of four years from impugned order.
Notice u/s 142(1) was issued to petitioner, but respondent failed to state when it was delivered/served, violating principles of natural justice. Impugned order deserves to be set aside adopting justice-oriented approach, granting petitioner opportunity to reply to Section 142 notice. Respondent entitled to claim interest on demand amount if order passed against petitioner after remand due to lapse of four years from impugned order.
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