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 Supreme Court dismissed the appeal filed by the Revenue seeking condonation of a 220-day delay in filing the special leave petition. The Court found the reasons assigned for the delay unsatisfactory and insufficient to be condoned. Consequently, the special leave petition was dismissed on the ground of delay. However, the Court left open the question of law regarding the accrual of interest on securities, whether computed on an accrual basis or on the due date as per the terms and conditions of the security, to be agitated in any other appropriate case.
The Supreme Court dismissed the appeal filed by the Revenue seeking condonation of a 220-day delay in filing the special leave petition. The Court found the reasons assigned for the delay unsatisfactory and insufficient to be condoned. Consequently, the special leave petition was dismissed on the ground of delay. However, the Court left open the question of law regarding the accrual of interest on securities, whether computed on an accrual basis or on the due date as per the terms and conditions of the security, to be agitated in any other appropriate case.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
