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...
Customs broker's license revocation and penalty set aside. CESTAT held time limit for issuing show cause notice under CBLR as mandatory, breached here. Charges under regulations 10(d) and 10(e) of CBLR not substantiated with evidence against customs broker's due diligence and proper advice to client. Impugned order unsustainable due to delay in issuing notice and lack of grounds. Appeal allowed.
Customs broker's license revocation and penalty set aside. CESTAT held time limit for issuing show cause notice under CBLR as mandatory, breached here. Charges under regulations 10(d) and 10(e) of CBLR not substantiated with evidence against customs broker's due diligence and proper advice to client. Impugned order unsustainable due to delay in issuing notice and lack of grounds. Appeal allowed.
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