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...
Revocation of customs broker license challenged due to lack of specific allegations in show cause notice regarding violations of Regulations 11(n) and 17(9) of 2013 Customs Brokers Licensing Regulations. Show cause notice merely reproduced Additional Commissioner's order without detailing reasons for alleged violations. Commissioner's order found deficient as it did not consider broker's reply and based findings solely on Additional Commissioner's order. Tribunal held show cause notice defective for not spelling out specific charges, rendering Commissioner's order unsustainable on grounds of violation of principles of natural justice. Order set aside for lack of proper opportunity to broker to defend charges.
Revocation of customs broker license challenged due to lack of specific allegations in show cause notice regarding violations of Regulations 11(n) and 17(9) of 2013 Customs Brokers Licensing Regulations. Show cause notice merely reproduced Additional Commissioner's order without detailing reasons for alleged violations. Commissioner's order found deficient as it did not consider broker's reply and based findings solely on Additional Commissioner's order. Tribunal held show cause notice defective for not spelling out specific charges, rendering Commissioner's order unsustainable on grounds of violation of principles of natural justice. Order set aside for lack of proper opportunity to broker to defend charges.
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TaxTMI 
TaxTMI 
of 4879 
