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 High Court declined to entertain the petition challenging the Order-in-Original issued by the Principal Commissioner of CGST and Central Excise, Pune. The Court held that no case was made out to deviate from the usual practice of requiring the party to exhaust the alternate statutory appeals available. Regarding the requirement of pre-deposit, the Court observed that the petitioner, being a multi-national company, cannot bypass the alternate remedy on such grounds. However, the Court granted liberty to the petitioner to challenge the notification dated March 31, 2023, if the occasion arises after exhausting the statutory remedies, keeping all contentions of parties open in this regard. The petition was disposed of.
The High Court declined to entertain the petition challenging the Order-in-Original issued by the Principal Commissioner of CGST and Central Excise, Pune. The Court held that no case was made out to deviate from the usual practice of requiring the party to exhaust the alternate statutory appeals available. Regarding the requirement of pre-deposit, the Court observed that the petitioner, being a multi-national company, cannot bypass the alternate remedy on such grounds. However, the Court granted liberty to the petitioner to challenge the notification dated March 31, 2023, if the occasion arises after exhausting the statutory remedies, keeping all contentions of parties open in this regard. The petition was disposed of.
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TaxTMI 
TaxTMI 
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