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 HC granted partial relief to the petitioner by allowing operation of the frozen bank account, subject to the condition that the existing balance exceeding Rs. 6.00 Crores remain untouched until the CIT(A) disposes of the appeal within six weeks. The petitioner may deposit additional funds and withdraw those amounts for business purposes. The court directed the CIT(A) to expeditiously adjudicate the appeal in accordance with law, balancing the petitioner's operational needs against the Revenue's claim. This interim order preserves the status quo on the substantial existing funds while enabling limited liquidity to prevent business paralysis.
The HC granted partial relief to the petitioner by allowing operation of the frozen bank account, subject to the condition that the existing balance exceeding Rs. 6.00 Crores remain untouched until the CIT(A) disposes of the appeal within six weeks. The petitioner may deposit additional funds and withdraw those amounts for business purposes. The court directed the CIT(A) to expeditiously adjudicate the appeal in accordance with law, balancing the petitioner's operational needs against the Revenue's claim. This interim order preserves the status quo on the substantial existing funds while enabling limited liquidity to prevent business paralysis.
Note: It is a system-generated summary and is for quick reference only.