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 dismissed the writ petition filed by the petitioner challenging issuance of DRC-01, holding that the department did not accept the petitioner's initial reply and issued DRC-01; once the petitioner files a substantive reply to DRC-01 the department must pass a detailed, speaking order explaining reasons for any rejection. The court declined to adjudicate the underlying tax adjustment dispute at this interim stage and refused relief, but granted the petitioner liberty to file a reply to DRC-01 within two weeks of receipt of the order. On receipt, respondents must consider and decide the matter by a reasoned order within four weeks. Petition dismissed.
The HC dismissed the writ petition filed by the petitioner challenging issuance of DRC-01, holding that the department did not accept the petitioner's initial reply and issued DRC-01; once the petitioner files a substantive reply to DRC-01 the department must pass a detailed, speaking order explaining reasons for any rejection. The court declined to adjudicate the underlying tax adjustment dispute at this interim stage and refused relief, but granted the petitioner liberty to file a reply to DRC-01 within two weeks of receipt of the order. On receipt, respondents must consider and decide the matter by a reasoned order within four weeks. Petition dismissed.
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TaxTMI 
TaxTMI 
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