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 challenging Income Tax Department's inquiry into alleged illegal cash transactions. Petitioner failed to establish violation of fundamental or statutory rights, with dispute primarily rooted in matrimonial conflict between petitioner and respondent. Court determined case involved complex factual disputes beyond Income Tax Department's jurisdiction and unsuitable for adjudication under Article 226. Complaint lacked statutory basis under Income Tax Act, 1961, with no formal regulatory mechanism invoked. Absence of legal framework for complaint submission rendered claims of rights violation non-existent. Court found no merit in arguments regarding department's non-response to complaint given its non-statutory nature.
HC dismissed petition challenging Income Tax Department's inquiry into alleged illegal cash transactions. Petitioner failed to establish violation of fundamental or statutory rights, with dispute primarily rooted in matrimonial conflict between petitioner and respondent. Court determined case involved complex factual disputes beyond Income Tax Department's jurisdiction and unsuitable for adjudication under Article 226. Complaint lacked statutory basis under Income Tax Act, 1961, with no formal regulatory mechanism invoked. Absence of legal framework for complaint submission rendered claims of rights violation non-existent. Court found no merit in arguments regarding department's non-response to complaint given its non-statutory nature.
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TaxTMI 
TaxTMI 
of 4879 
