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 writ petition challenging GST proceedings, holding that mere rejection of cross-examination request does not automatically vitiate administrative proceedings. The Court emphasized that parties cannot convert show cause notice proceedings into mini-trials and must provide specific reasons for cross-examination. The petitioner was directed to exhaust statutory appellate remedies under Section 107 of CGST Act by filing an appeal before the Appellate Authority within thirty days, thereby preserving the administrative order and maintaining procedural integrity.
HC dismissed the writ petition challenging GST proceedings, holding that mere rejection of cross-examination request does not automatically vitiate administrative proceedings. The Court emphasized that parties cannot convert show cause notice proceedings into mini-trials and must provide specific reasons for cross-examination. The petitioner was directed to exhaust statutory appellate remedies under Section 107 of CGST Act by filing an appeal before the Appellate Authority within thirty days, thereby preserving the administrative order and maintaining procedural integrity.
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