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...
The AT partially allowed the appeal, finding procedural defects in the provisional attachment order (PAO) for a specific property. The tribunal determined that the PAO was issued after amendments to PMLA incorporating Prevention of Corruption Act provisions, thus not retrospectively invalid. However, the order was set aside due to failure to issue show cause notice (SCN) to the co-owner as mandated under Section 8(1) of PMLA. Consequently, the PAO for the specific flat at Patel Nagar was quashed, with the attachment order being declared invalid for procedural non-compliance.
The AT partially allowed the appeal, finding procedural defects in the provisional attachment order (PAO) for a specific property. The tribunal determined that the PAO was issued after amendments to PMLA incorporating Prevention of Corruption Act provisions, thus not retrospectively invalid. However, the order was set aside due to failure to issue show cause notice (SCN) to the co-owner as mandated under Section 8(1) of PMLA. Consequently, the PAO for the specific flat at Patel Nagar was quashed, with the attachment order being declared invalid for procedural non-compliance.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
