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...
Petitioner's NRO account deposits were subject to TDS deduction; transferred shares from deceased wife's account not taxable. Respondents classified petitioner as resident, demanded tax on deposits as unexplained investments and transferred shares as purchase of securities. Petitioner unable to explain due to wife's demise and personal commitments. Order passed without opportunity of hearing, violating natural justice. Order set aside, matter remanded for fresh consideration after allowing petitioner to file reply/objections and personal hearing.
Petitioner's NRO account deposits were subject to TDS deduction; transferred shares from deceased wife's account not taxable. Respondents classified petitioner as resident, demanded tax on deposits as unexplained investments and transferred shares as purchase of securities. Petitioner unable to explain due to wife's demise and personal commitments. Order passed without opportunity of hearing, violating natural justice. Order set aside, matter remanded for fresh consideration after allowing petitioner to file reply/objections and personal hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
