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 found a violation of Section 75(7) where the demand amount (Rs. 59,27,500/-) exceeded the show-cause notice amount (Rs. 28,15,200/-). Despite procedural irregularities in hearing scheduling, the court primarily focused on the statutory non-compliance. The impugned order was set aside, and the matter was remanded to the respondent to provide proper opportunity of hearing and issue a fresh order in accordance with legal provisions, thereby allowing the petition and ensuring procedural fairness.
HC found a violation of Section 75(7) where the demand amount (Rs. 59,27,500/-) exceeded the show-cause notice amount (Rs. 28,15,200/-). Despite procedural irregularities in hearing scheduling, the court primarily focused on the statutory non-compliance. The impugned order was set aside, and the matter was remanded to the respondent to provide proper opportunity of hearing and issue a fresh order in accordance with legal provisions, thereby allowing the petition and ensuring procedural fairness.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
