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...
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HC dismissed the appeal concerning condonation of delay in filing second appeal regarding misdeclaration of imported Brass Ceramic Cartridges. The appellant failed to demonstrate due diligence in verifying the Commissioner (Appeals) order status. Despite proper service of hearing notice to both appellant and counsel, and counsel's attendance at hearing, appellant neglected to provide alternative address for order service. The Department fulfilled procedural obligations by sending order to available address. Court held appellant's inaction and counsel's failure to communicate constituted negligence. The CESTAT's order upholding dismissal was affirmed, as delay in filing was attributable to appellant's lack of vigilance rather than departmental oversight.
HC dismissed the appeal concerning condonation of delay in filing second appeal regarding misdeclaration of imported Brass Ceramic Cartridges. The appellant failed to demonstrate due diligence in verifying the Commissioner (Appeals) order status. Despite proper service of hearing notice to both appellant and counsel, and counsel's attendance at hearing, appellant neglected to provide alternative address for order service. The Department fulfilled procedural obligations by sending order to available address. Court held appellant's inaction and counsel's failure to communicate constituted negligence. The CESTAT's order upholding dismissal was affirmed, as delay in filing was attributable to appellant's lack of vigilance rather than departmental oversight.
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