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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The HC quashed the impugned Assessment Order dated 12.02.2025 and remitted the matter to the 2nd Respondent for fresh adjudication. The remittal is conditional: the Petitioner must deposit 25% of the disputed tax in cash from the Petitioner's Electronic Cash Register within thirty days of receipt of the order. The HC observed that similar relief had been granted previously under analogous circumstances and found no reason for a different approach. The petition is disposed of by way of remand, subject to compliance with the deposit condition, failing which the Respondent may proceed in accordance with law.
The HC quashed the impugned Assessment Order dated 12.02.2025 and remitted the matter to the 2nd Respondent for fresh adjudication. The remittal is conditional: the Petitioner must deposit 25% of the disputed tax in cash from the Petitioner's Electronic Cash Register within thirty days of receipt of the order. The HC observed that similar relief had been granted previously under analogous circumstances and found no reason for a different approach. The petition is disposed of by way of remand, subject to compliance with the deposit condition, failing which the Respondent may proceed in accordance with law.
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