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...
SC held that the Limitation Act applies comprehensively to recovery proceedings. Section 18 permits limitation period extension when liability is acknowledged, particularly where payment time has not yet matured. The respondents' technical objections were deemed dilatory, as they were aware of previous judicial determinations. The High Court's order was set aside, with writ petitions to be restored and heard after disposal of pending intra-court appeals. The limitation period for recovery proceedings was effectively extended due to respondents' liability acknowledgment, enabling the appellant to pursue legal remedies within prescribed timelines.
SC held that the Limitation Act applies comprehensively to recovery proceedings. Section 18 permits limitation period extension when liability is acknowledged, particularly where payment time has not yet matured. The respondents' technical objections were deemed dilatory, as they were aware of previous judicial determinations. The High Court's order was set aside, with writ petitions to be restored and heard after disposal of pending intra-court appeals. The limitation period for recovery proceedings was effectively extended due to respondents' liability acknowledgment, enabling the appellant to pursue legal remedies within prescribed timelines.
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TaxTMI 
TaxTMI 
of 4879 
