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...
HC dismissed petition for complete stay of demand. Petitioner directed to pay 20% of Rs. 5.86 crore demand in 6 installments. Additions made by AO on account of non-genuine purchases based on search, statements and investigation. Petitioner failed to rebut findings or prove purchases were genuine. No prima facie case made out for full stay or financial incapacity shown to pay 20% demand.
HC dismissed petition for complete stay of demand. Petitioner directed to pay 20% of Rs. 5.86 crore demand in 6 installments. Additions made by AO on account of non-genuine purchases based on search, statements and investigation. Petitioner failed to rebut findings or prove purchases were genuine. No prima facie case made out for full stay or financial incapacity shown to pay 20% demand.
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TaxTMI 
TaxTMI 
of 4878 
